Privacy Policy

Last updated 11 October 202

Introduction

I am committed to safeguarding the privacy of my website visitors.

This policy applies where I am acting as a data controller. It is about how I manage the personal data of my website visitors. I other words, where I determine the purposes and means of the processing of that personal data.

I use cookies on my website. Some cookies are not strictly necessary for the provision of my website. When you first visit my website I will ask you to consent to my use of cookies.

In this policy, “I”, “me” and “my” refer to Linda Winter, Artist.

How I use your personal data

In this Section I have set out:

  1. the general categories of personal data that I may process;
  2. the purposes for which I may process personal data; and
  3. the legal bases of the processing.

Usage data

I may process data about your use of my website (“usage data”). The usage data may include your IP address, and geographical location. It can also include browser type and version, operating system, and referral source. Also the length of visit, page views and website navigation paths. The source of the usage data is my analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is my legitimate interests. Which are monitoring and improving my website.

Account data

I may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating my website. Also for ensuring the security of my website, and maintaining back-ups of my databases. And also for communicating with you. The legal basis for this processing is my legitimate interests. Which in this case are the proper administration of my website.

Profile data

I may process your “profile data”. That is information included in your personal profile on my website. Profile data may include your name, web address, telephone number, and email address. It may also include profile pictures, interests, qualifications, educational details and employment details. The profile data may be processed to enable collaboration between website registered users. The legal basis for this processing is my legitimate interests. That is the proper administration of my website.

Publication data

I may process anything that you post for publication on my website (“publication data”). This data may be processed to enable such publication and administering my website. The legal basis for this processing is my legitimate interests. That is the proper administration of my website.

Notification data

You may provide information to subscribe to email notifications and/or newsletters. I may process such “notification data”. I will do so to send you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

Correspondence data

Any communication that you send to me will contain, and have related to it, information. This is “correspondence data”. I may process such data. The correspondence data may include the communication content. It can also include metadata associated with the communication. If you use a contact form on my website, the website will create the associated metadata. The correspondence data may be processed to communicate with you and for record-keeping. The legal basis for this processing is my legitimate interests. Namely the proper administration of my website and organization and communications with users.

Do-not-contact data

I may process requests that I not contact you (“do-not-contact data”). This data may include your email address, your physical address, your phone number. This data may be processed for ensuring I don’t contact you. The legal basis for this processing is my legitimate interests. Namely ensuring I don’t contact you when you don’t want it.

Necessary use

I may process any of your personal data identified in this policy where necessary for:

  1. Establishment, exercise or defence of legal claims. Whether such claims are in court proceedings or an administrative or out-of-court procedure. The legal basis for this processing is my legitimate interests. Namely the protection and assertion of my and your legal rights, and the legal rights of others.
  2. Purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is my legitimate interests. Namely my proper protection against risks.
  3. Compliance with a legal obligation to which I am subject.
  4. Protecting your vital interests or the vital interests of another natural person.

Only your own information

Please do not supply any other person’s personal data to me, unless I prompt you to do so.

Providing your personal data to others

I may disclose your personal data to my insurers and/or professional advisers. That is insofar as reasonably necessary for:

  1. The purposes of obtaining or maintaining insurance coverage.
  2. Managing risks.
  3. Obtaining professional advice.
  4. The establishment, exercise or defence of legal claims. Whether such claims are in court proceedings or an administrative or out-of-court procedure.

Besides the specific disclosures above, I may disclose your personal data:

  1. When necessary for compliance with a legal obligation to which I am subject.
  2. To protect your vital interests or the vital interests of another natural person.

International transfers of your personal data

This Section is about when your data may be sent outside the European Economic Area (EEA).

The hosting facilities for my website are situated in the Netherlands.

You acknowledge that, via the Internet, Publication Data is available around the world. I cannot prevent the use (or misuse) of such personal data by others.

Retaining and deleting personal data

This Section sets out my data retention policies and procedures. These are designed to help ensure my compliance with legal obligations. That is in relation to the retention and deletion of personal data.

I will not keep personal data that I process for longer than is necessary for the purpose or purposes I keep it for.

I will keep your personal data as follows:

Type of Data Period starts on / from Shortest period Longest period
Usage Data recorded two years three years
Account Deletion of account six years seven years
Profile Deletion of profile six years seven years
Publication Deletion from website six years seven years
Notification Unsubscribing from all notifications and newsletters six years seven years
Correspondence Last communication to or from you six years seven years

In some cases it is not possible to specify in advance the periods for which I will keep your personal data. In such cases, I will determine the period of retention based on the following criteria:

  1. I will keep Do-not-contact data forever or until you ask me to resume contact.

In spite of the other provisions of this Section, I may keep your personal data when necessary for:

  1. Compliance with a legal obligation to which I am subject.
  2. Protecting your vital interests or the vital interests of another natural person.

Amendments

I may update this policy from time to time by publishing a new version on my website.

You should check this page from time to time to ensure you are happy with any changes to this policy.

When I make changes I will change the “Last updated” date at the top of this page.

Your rights

In this Section, I have summarised the rights that you have under data protection law. Some of the rights are complex. I have not included all the details in my summaries. For a full explanation see the relevant laws and guidance from regulatory authorities.

Your principal rights under data protection law are the right to:

  1. Access.
  2. Rectification.
  3. Erasure.
  4. Restrict processing.
  5. Object to processing.
  6. Data portability.
  7. Complain to a supervisory authority.
  8. Withdraw consent.

Access

You have the right to: confirmation about whether I process your personal data. Where I do, access to the personal data, together with certain extra information. That extra information includes:

  1. Details of the purposes of the processing.
  2. The categories of personal data concerned.
  3. The recipients of the personal data.

Providing the rights and freedoms of others are not affected, I will supply to you a copy of your personal data. I will send the first copy free of charge, but extra copies may be subject to a reasonable fee.

Rectification

You have the right to have any:

  1. Inaccurate personal data about you rectified.
  2. Incomplete personal data about you completed, taking into account the purposes of processing.

Erasure and restriction

In some circumstances you have the right to erasure of your personal data. This must happen without undue delay. Those circumstances include:

  1. You contest the accuracy of the personal data.
  2. Processing is unlawful but you oppose erasure.
  3. I no longer need the personal data for the purposes of my processing. With you needing the data for establishment, exercise or defence of legal claims.
  4. You have objected to processing, pending the verification of that objection.

Where processing has been so restricted, I may continue to store your personal data. I will only process it:

  1. With your consent.
  2. For the establishment, exercise or defence of legal claims.
  3. To protect the rights of another natural or legal person.
  4. For reasons of important public interest.

Object to processing

You have the right to object to my processing of your personal data. That is on grounds relating to your particular situation. But only to the extent that the legal basis for the processing is that the processing is necessary for:

  1. Performing a task carried out in the public interest.
  2. Exercising any official authority vested in me.
  3. Purposes of the legitimate interests pursued by me or by a third party.

If you make such an objection, I will stop processing the personal information unless:

  1. I can show compelling legitimate grounds for the processing. Where such grounds override your interests, rights and freedoms.
  2. The processing is for the establishment, exercise or defence of legal claims.

You can object to my processing of your personal data for direct marketing purposes. Such purposes include profiling for direct marketing purposes. If you make such an objection, I will stop processing your personal data for this purpose.

You have the right to object to my processing of your personal data for:

  1. Scientific or historical research purposes.
  2. Statistical purposes.
  3. On grounds relating to your particular situation. That is unless the processing is needed to perform a task carried out in the public interest.

Data portability

You have a right to your data in a structured commonly used machine-readable format, if:

  1. The legal basis for my processing of your personal data is consent. Such processing is carried out by automated means.

This right does not apply where it would adversely affect the rights and freedoms of others.

Complain to a supervisory authority

You may consider that my processing of information infringes data protection laws. If you do then you have a legal right. That right is to lodge a complaint. You should lodge the complaint with a supervisory authority responsible for data protection. You may do so in the EU member state: you live in; of your place of work; or of the alleged infringement.

Withdraw consent

If the basis for processing information is consent, you can withdraw that consent. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Exercising your rights

You may exercise any of your rights in relation to personal data by emailing me. To email me please use my contact form.

Cookies

My Cookie Policy covers what cookies are and how this site uses them. This Privacy Policy includes the Cookie Policy.

Credit

I used a template from SEQ Legal to create the first version of this policy.