God’s Lily Privacy Policy

Before you read the legal bit further down I had better explain why all this malarkey is necessary. Apparently, because you can fill in a form with your name and address to help us provide a service to you God’s Lily become a data processor.  It gets even more amazing though when you realise that the software that is used to develop all the God’s Lily websites also collects enough data to make God’s Lily into a data processor. Yikes these rules are strict.

On some of the websites run by God’s Lily, it is possible to access a membership area (usually after paying the subscription fee). When we do that we have to store the data needed to make it possible for people to access the membership areas of those sites.

The law says that as a data processor we have to take great care of the information you pass on to us. To be honest that is really common sense when you think about it but what seems common sense to us mere mortals is not enough to comply with the law.  There again we are dealing with information about identifiable human beings so it is only right to handle it with care and respect as you would a real person.

Have we got it right?

There is no way that we can know if you have given us the right information, although if there is a name like Donald Duck or Bugs Bunny in the list of members it does become rather suspicious. Entering the right information into a form has to be the responsibility of the person entering the data. That is common sense really isn’t it?

We can all make mistakes and making a mistake like that is not the unpardonable sin but it cannot be corrected unless you speak up. However, one of the aims of General Data Protection Regulations is to make sure those who collect information make it easy for those who give them that information to correct it and even withdraw their permission to use it.

Where is it stored and who can access it?

The information you enter into the registration forms on our sites is stored safely on a server here in the UK. It is locked away behind a passworded system and access is only given when necessary. Occasionally it is necessary to allow a contractor into the area where the data is stored. In that situation, temporary access is given for as long as it is necessary. After that, the area is locked again. However, these are professionals who are only interested in helping me help provide you with the best possible service.

It has proved necessary to use the services of third parties in order to provide the quality of service that you as a customer would expect. One of these services provides us with the ability to send out emails. They believe that they have done all that is necessary to comply with GDPR. If not I would not still be using them. You will be able to check how they do this by checking the small print in a recent email. This includes a link to a web page that will help you do all the things that you have the right to do under GDPR.

The other one improves our ability to offer a good buying experience to our clients. They make it easier for us to track the payments you have made. It also makes it easier for you to change your payment details if this ever becomes necessary. Well, credit cards do not last forever and replacement cards do not necessarily have the same numbers on them as their predecessors. Those details are securely stored on the servers used by our suppliers.

Oh crumbs I thought that would be all but then there was the stall at the carnival. Oh no now we need to come up with more ways of protecting people’s privacy. The biggest issue was how to handle the completed forms as these include names and contact details. That is when we came up with the idea of having a postbox on the stall. It is made from a strong cardboard box wrapped like a parcel with a slit in the top. It would take a very determined person to get the completed forms out of the slit. Not only that but it would take some time and effort to unwrap and open the box which would make it a considerable deterrent to anyone thinking of opening the box at the carnival. It would only be opened in the privacy of the workspace used by God’s Lily.

Once retrieved from the sealed box the forms are stored with the accounts and other important papers in a room that is used solely as a workspace for God’s Lily. The email addresses collected are added to a third party service called MailChimp. There is a dedicated list within the account that is segmented according to the dates that the contact form was completed.

There are times when we use an online form that has been set up using Google forms. Google, of course, has its own privacy policy. The information collected is downloaded in the form of a spreadsheet so that it can be uploaded into MailChimp. The spreadsheet is stored together with the accounts and other information that God’s Lily does not want anyone else getting their hands on.

What is the reasoning behind the registration form and the opt in form?

1. The obvious thing is we ask you to complete a form so that we can start a customer client relationship. It makes perfect sense to me to ask you what you would like to call you in any communications. Not only that it also makes great sense being able to contact you if it ever proved necessary. You would expect this if you enrolled on a college course and to be honest the registration forms used on this site ask you for a lot less information than most college enrollment forms I have ever seen.

2. It is necessary to have a certain amount of information to enable you to gain access to our membership area. When you pass on your email details it makes it possible for us to send you the instructions on how to access the membership area. There are times when we use that information to inform you of other things in relation to the membership area such as when new content has been added.

3. There are times when we want to contact you regarding other things. One of the forms on the site makes it possible for you to receive blog broadcasts. This means that it is easier for you to receive copies of new articles added to the site.

4. Being a Christian site any competition will be based on skill rather than chance but if any such competition is run email is the tool of choice to inform you of it.

Other reasons why we collect data

In addition to the forms where you enter data we collect information about our visitors. This information is not about who you are but about what people do. The aim is to work out how many people visit the site and to record what pages they visit.

1. Another reason why we gather data is to administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) In other words we need a certain amount of information in order to make it possible to stay in business and make it possible to meet our legal responsibilities.

2. There are times when we gather data to show what content or advertising is achieving the goals that we want to reach. There is no point paying for advertising that does not produce the response we need to have to meet our bills and provide the service customers expect us to provide. If advertising does not pay for itself then there will be no service provided and that will not benefit either you or us.

3. Another important reason why we gather data is to improve the service that we provide you with. We can better serve our customers if we know what they are interested in. The only way to do this is to check what pages have been visited.

Just to make sure everything has been covered here is the legal verbiage it has been suggested that is used on this site. Well, actually there were two good sources that we discovered. We made one into part one. The other which goes into a bit more detail about the website itself has become part two.

Privacy Policy – Part one

God’s Lily is committed to safeguarding your privacy. Contact us at if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.

By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy.

Table of Contents

  1. Definitions used in this Policy
  2. Data protection principles we follow
  3. What rights do you have regarding your Personal Data
  4. What Personal Data we gather about you
  5. How we use your Personal Data
  6. Who else has access to your Personal Data
  7. How we secure your data
  8. Information about cookies
  9. Contact information

Definitions

Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us  – refers to Susan Parnaby acting in the name of God’s Lily

Data Protection Principles

We promise to follow the following data protection principles:

  • Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
  • Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
  • Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
  • Processing is limited with a time period. We will not store your personal data for longer than needed.
  • We will do our best to ensure the accuracy of data.
  • We will do our best to ensure the integrity and confidentiality of data.

Data Subject’s rights

The Data Subject has the following rights:

Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.

Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.

Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.

Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.

Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.

Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.

Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.

Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.

Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.

Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.

Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.

Data we gather

Information you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.

Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.

Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. Our partners are.

MailChimp – You can view their privacy policy at https://mailchimp.com/legal/privacy/

ThriveCart – you can view their privacy policy at https://legal.thrivecart.com/platform/privacy/https://legal.thrivecart.com/platform/privacy/

Publicly available information
We might gather information about you that is publicly available.

How we use your Personal Data

We use your Personal Data in order to:

  • provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
  • enhance your customer experience;
  • fulfil an obligation under law or contract;

We use your Personal Data on legitimate grounds and/or with your Consent.

On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:

  • to identify you;
  • to provide you a service or to send/offer you a product;
  • to communicate either for sales or invoicing;

On the ground of legitimate interest, we Process your Personal Data for the following purposes:

  • to send you personalized offers* (from us and/or our carefully selected partners);
  • to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
  • to conduct questionnaires concerning client satisfaction;
  • to do anything else as that is listed in the list about the reasoning for you filling in the forms on the site.

As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.

With your consent we Process your Personal Data for the following purposes:

  • to send you newsletters and campaign offers (from us and/or our carefully selected partners);
  • for other purposes we have asked your consent for;

We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than is necessary.

We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:

  • the link between purposes, context and nature of Personal Data is suitable for further Processing;
  • the further Processing would not harm your interests and
  • there would be appropriate safeguard for Processing.

We will inform you of any further Processing and purposes.

Who else can access your Personal Data

We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:

Our processing partners:

  • MailChimp – You can view their privacy policy at https://mailchimp.com/legal/privacy/
  • ThriveCart – you can view their privacy policy at https://legal.thrivecart.com/platform/privacy/https://legal.thrivecart.com/platform/privacy/

Our business partners:

  • God’s Lily has a number of different websites and products. For example The COB Club is a website that is provided by God’s Lily

Connected third parties:

  • Google analytics

We only work with Processing partners who are able to ensure an adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

How we secure your data

We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data. We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.

Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

If you have an account with us, note that you have to keep your username and password secret.

Children

We do not intend to collect or knowingly collect information from children. We do not target children with our services.

Cookies and other technologies we use

We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.

A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

We use cookies for the following purposes:

  • Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
  • Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
  • Analytics cookies – these cookies are used to track the use and performance of our website and services
  • Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

Privacy Policy part Two

Who we are

Our primary website address is: https://www.godslily.co.uk

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

The contact forms send an email to an address that is monitored on premises where there is virtually no risk of it being accidentally viewed.  Access to the premises is limited and the equipment used is not in clear view of visitors. (One of the advantages of lone working. )

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Security Log

The IP address of visitors, user ID of logged in users, and username of login attempts are conditionally logged to check for malicious activity and to protect the site from specific kinds of attacks. Examples of conditions when logging occurs include login attempts, log out requests, requests for suspicious URLs, changes to site content, and password updates. This information is retained for 60 days.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Security logs are retained for 60 days

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Additional information

How we protect your data

We do our best to protect our websites using a number of security plugins. These deal with the more obvious vulnerabilities inherent in this type of website. We have signed up to the newsletters sent out by those who provide the pieces of software that plug into this site. This enables us to keep up to date with developments.

What data breach procedures we have in place

 

Who we share your data with

This site is scanned for potential malware and vulnerabilities by Sucuri’s SiteCheck. We do not send personal information to Sucuri; however, Sucuri could find personal information posted publicly (such as in comments) during their scan. For more details, please see Sucuri’s privacy policy.

The future

We recognise that compliance with the legal requirements relating to privacy is not a once and for all procedure. It is something that you make a start with and keep on improving.  Our understanding of how Data Protection law impacts what we do will change over time.

This policy reflects our knowledge and understanding at the date given below.  We are well aware that as other people and organisations catch up and answer requests for information that more information will become available. There will updates to this policy in the future.

Contact Information

Supervisory Authority

Information Commissioner’s Office

Cardiff

Data Controller

Susan acting as God’s Lily can be contacted via the forms on this site.  (Sadly in the interest of maintaining her own security she has decided not to include her full address online. This is one of the downsides of lone working.)

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy.
Last modification was made on 13th July 2018

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