MirabelleMakery

Privacy Policy
Mirabelle Makery
Last updated on 12th October 2022
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors (including third party platforms and services: Etsy, Facebook, Instagram, Pinterest, PayPal, Stripe, Mailchimp, Royal Mail, Go Daddy, Gmail, Squarespace, Square Reader, Google Analytics, Microsoft Outlook, Zoom, Dubsado, Awin and Rakuten) and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors (including third party platforms) and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You can access the privacy controls via https://kb.mailchimp.com/accounts/login/set-account-security-options

1.5 In this policy, "we", "us" and "our" refer to Mirabelle Makery. For more information about us, see Section 13.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website, third party platforms and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is part of our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data and/or contractual data created by orders and/or correspondence ("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 our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and/or our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process your information included in your personal profile on our website or third party platform ("profile data"). The profile data may include your name, address, telephone number and email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent and/or our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.5 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, address, telephone number and email address. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and/or our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.6 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent and/or our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent and/or our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.8 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent and/or our legitimate interests, namely the proper management of our customer relationships.
3.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website or third party website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
3.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.11 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.12 N/A
3.13 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.14 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.15 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.16 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 N/A
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose your name, address, email address and telephone to our suppliers or subcontractors identified at https://www.royalmail.com or other insofar as reasonably necessary for fulfilling a contract.
4.4 Financial transactions relating to our website and services are handled by our payment services providers, PayPal, Stripe and Square Reader (Sqaureup International Ltd). We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at: https://www.paypal.com/uk/webapps/mpp/ua/legalhub-full?locale.x=en_GB
https://stripe.com/gb/privacy
https://squareup.com/gb/legal/privacy-no-account

4.5 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have offices and facilities in the United Kingdom. The European Commission has made an "adequacy decision" with respect to the data protection laws in this country.
5.3 The hosting facilities for our website are situated in the United States of America. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en
5.4 Mailchimp, Squarespace, Instagram, Pinterest, Facebook, PayPal, Stripe, Squareup International Ltd, Gmail/Google, Google Analytics, Etsy, Microsoft Outlook, Dubsado, Awin, Zoom, Rakuten, and Go Daddy are situated in the United States/UK and/or Ireland (Pinterest – both, depending on the users location) The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en

5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Personal data and related correspondence will be retained for a minimum period of 1 year and for a maximum period of 7 years following consent.
(b) Mailing list name and email address details will be retained for the length of the contract from the subscription date made by you to the unsubscription date made by you.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data will be determined based on business and legal requirements.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email or through the private messaging system on our website. This policy will always be available to view on www.mirabellemakery.com
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure (be forgotten);
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data 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: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
• Authentication, Personalization And Security. Cookies help us verify your Account and device and determine when you’re logged in, so we can make it easier for you to access the Services and provide the appropriate experiences and features. We also use cookies to help prevent fraudulent use of login credentials.
• Performance And Analytics. Cookies help us analyze how the Services are being accessed and used, and enable us to track performance of the Services. For example, we use cookies to determine if you viewed a page or opened an email. This helps us provide you with information that you find interesting. We also use cookies to provide insights regarding your End Users and Your Sites’ performance, such as page views, conversion rates, device information, visitor IP addresses and referral sites.
• Third Parties. Third Party Services may use cookies to help you sign into their services from our Services. We also may use third party cookies, such as Google Analytics, to assist with analyzing performance. Any third party cookie usage is governed by the privacy policy of the third party placing the cookie.
You can find out more about cookies here: http://www.allaboutcookies.org

• Squarespace Ads. We partner with third party publishers, advertising networks and service providers to manage our ads on other sites. Our third party partners may set cookies on your device or browser to gather information about your activities on the Services and other sites you visit, in order to provide you with Squarespace ads. For example, if you visit Squarespace and also use a social media platform, you may see a Squarespace ad in your social media newsfeed or timeline.
Affiliate links and cookies
• Rakuten, a third party affiliate marketing network, uses cookies to help make sure I get a commission when you buy a product after clicking on a link or ad banner that takes you to the site of one of their merchants. You can read their Privacy Policy here and Cookie Policy here
• Awin, a third party affiliate marketing network, uses cookies to help make sure I get a commission when you buy a product after clicking on a link or ad banner that takes you to the site of one of their merchants. You can read their Privacy Policy here and Cookie Policy here

• Opting Out. You can set your browser to not accept cookies, but this may limit your ability to use the Services. We currently don’t respond to DNT:1 signals from browsers visiting our Services. You can also opt out of receiving interest-based ads from certain ad networks here (or if located in the European Union, here).
10.2 Pixels. A pixel tag, or pixel, is a small piece of code that can be embedded on websites and emails. We use pixels to learn how you interact with our site pages and emails, and this information helps us and our ad partners provide you with a more tailored experience. For example, if you visit a Squarespace page related to music, a pixel will help us show you an ad for that page when you later visit a music news site.
10.3 Device Identifiers. We use device identifiers to track, analyze and improve the performance of the Services and our ads.

11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/
Cookie Policy available at https://policies.google.com/technologies/ads?hl=en

11.3 We use Square space to host our website. This service uses cookies. You can view the privacy policy of this service provider at https://www.squarespace.com/privacy-new/ and their cookie policy at https://www.squarespace.com/cookie-policy/

11.4 We use Etsy to sell our products on. This service uses cookies. You can view the privacy policy of this service provider at https://www.etsy.com/uk/legal/privacy and their cookie policy at https://www.etsy.com/legal/cookies/

11.5 We use Facebook for social media. This service uses cookies. You can view the privacy policy of this service provider at
https://m.facebook.com/about/privacyshield and their cookie policy at https://www.facebook.com/policies/cookies/

11.6 We use Instagram for social media. This service uses cookies. You can view the privacy policy of this service provider at https://help.instagram.com/519522125107875?helpref=page_content and their cookie policy at https://help.instagram.com/1896641480634370?ref=ig

11.7 We use Pinterest for social media. This service uses cookies. You can view the privacy policy of this service provider at
https://policy.pinterest.com/en-gb/privacy-policy and their cookie policy at https://policy.pinterest.com/en/cookies

11.8 We use PayPal to take payment for orders via Etsy or on our website. This service uses cookies. You can view the privacy policy of this service provider at https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev?locale.x=en_GB and their cookie policy at https://www.paypal.com/uk/webapps/mpp/ua/cookie-full

11.9 We use Royal Mail to post orders to you. This service uses cookies. You can view the privacy policy of this service provider at
https://www.royalmail.com/business/system/files/royal-mail-the-gdpr-opportunity-with-mail.pdf and their cookie policy at https://www.royalmail.com/cookies-policy/

11.10 We use Mail Chimp as our email service provider. This service uses cookies. You can view the privacy policy of this service provider at
https://mailchimp.com/legal/privacy/ and their cookie policy at https://kb.mailchimp.com/accounts/account-setup/how-mailchimp-uses-cookies

11.11 We use Google Analytics to analyze our data sources. This service uses cookies. You can view the privacy policy of this service provider at
https://policies.google.com/privacy?hl=en and their cookie policy at https://policies.google.com/technologies/ads?hl=en

11.12 We use Go Daddy to provide us with our domain name. This service uses cookies. You can view the privacy policy of this service provider at
https://uk.godaddy.com/agreements/showdoc.aspx
and their cookie policy at https://ie.godaddy.com/agreements/showdoc.aspx?pageid=24668

11.13 We use Microsoft Outlook to provide us with our email service. This service uses cookies. You can view the privacy policy of this service provider at
https://privacy.microsoft.com/en-gb/privacystatement and their cookie policy at https://privacy.microsoft.com/en-gb/privacystatement#maincookiessimilartechnologiesmodule

11.14 Rakuten, a third party affiliate marketing network, uses cookies to help make sure I get a commission when you buy a product after clicking on a link or ad banner that takes you to the site of one of their merchants. You can read their Privacy Policy here and Cookie Policy here

11.15 Awin, a third party affiliate marketing network, uses cookies to help make sure I get a commission when you buy a product after clicking on a link or ad banner that takes you to the site of one of their merchants. You can read their Privacy Policy here and Cookie Policy here

11.16 We use Stripe to take payment for orders on our website. This service uses cookies. You can view the privacy policy of this service provider at https://stripe.com/gb/privacy
and their cookie policy at https://stripe.com/cookies-policy/legal


11.17 We use Square Reader (Squareup International Ltd) to take payment for in person transactions. This service uses cookies. You can view the privacy policy of this service provider at https://squareup.com/gb/legal/privacy-no-account
and their cookie policy at https://squareup.com/gb/legal/privacy-no-account

11.18 We use Zoom software (Zoom.us) to provide live online classes. This service uses cookies. You can view the privacy policy of this service provider at https://uws.zoom.us/privacy and their cookie policy at https://zoom.us/cookie-policy

11.19 We use Dubsado as a business management platform and to host client portals. This service uses cookies. You can view the privacy policy of this service provider at https://www.dubsado.com/legal/privacy-policy








12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and operated by Charlotte Andrews.
13.2 N/A
13.3 Our principal place of business is at 3 Kennion Road, Wells, Somerset, BA5 2NP, United Kingdom
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by email, using the email address published on our website from time to time.

14. Data protection officer
14.1 Our data protection officer's contact details are as above in section 13.4.

END