Last Updated: May 2021
Your information will be held by Chloesha Ellen Designs
In this privacy notice, “We” “Our” “Us” and “They” is Chloesha Ellen Designs
1.1 We are committed to safeguarding the privacy of our website visitors and service users;
in this policy we explain how we will handle your personal data and how the law protects
you, in accordance with the General Data Protection Regulation (GDPR).
accordance with the terms of this policy.
2. How we use your personal data
2.1 In this section 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.
2.2 We may process data about your use of our website 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 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
2.3 We 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 or your employer. 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 our legitimate
interests, namely the proper administration of our website and business.
2.4 We may process your information included in your personal profile on our website
("profile data"). The profile data may include your name, address, telephone number, email
address, profile pictures, gender, date of birth, relationship status, interests and hobbies,
educational details and employment details. 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 our legitimate interests, namely the proper administration of our
website and business.
2.5 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 both company and personal
information. The source of the service data is you or your employer. 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 our legitimate interests,
namely the proper administration of our website and business.
2.6 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 our legitimate interests, namely the proper administration of our website
2.7 We may process information contained in any enquiry you submit to us regarding
products and/or services ("enquiry data"). The enquiry data may be processed for the
purposes of offering, marketing and selling relevant products and/or services to you. The
legal basis for this processing is consent.
2.8 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.
2.9 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.
2.10 We may process any of your personal data identified in the other provisions of 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.
2.11 In addition to the specific purposes for which we may process your personal data set
out in this Section 2, 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.
2.12 Please do not supply any other person's personal data to us, unless we prompt you to
3. Automated decision-making
3.1 We will use your personal data for the purposes of automated decision-making in relation
to our website and our processes.
3.2 This automated decision-making will involve marketing personalisation across our
website and other marketing communications such as email.
3.3 The significance and possible consequences of this automated decision-making are that
you are likely to receive a personalised experience with content and other marketing assets.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar
as reasonably necessary for the purposes of obtaining and maintaining insurance coverage,
managing risks, obtaining professional advice and managing legal disputes.
4.2 We may disclose personal data to our suppliers or subcontractors insofar as reasonably
necessary for them to complete any activity we have set out for them on our behalf.
4.3 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
which will govern that third party's use of your personal data.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may
also 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.
5. International transfers of your personal data
5.1 In this section, 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 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
5.3 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 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
then is necessary for that purpose or those purposes.
6.3 Your personal data will be retained for 6 years following the date and time of your last
interaction with our website or business, at the end of which period it will be deleted from our
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 your interaction with
our website or business.
6.5 Notwithstanding the other provisions of this section, 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
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your
personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store all your personal data on secure servers, personal computers and mobile
devices, and in secure manual record-keeping systems.
7.3 The following personal data will be stored by us in encrypted form: your name, contact
information, password(s) and cardholder data.
7.4 Data relating to your enquiries and financial transactions that is sent from your web
browser to our web server, or from our web server to your web browser, will be protected
using encryption technology.
7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data
over the internet is inherently insecure, and we cannot guarantee the security of data sent
over the internet.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to
9. Your rights
9.1 You may instruct us to provide you with any personal information we hold about you;
provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually
accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a
utility bill showing your current address).
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing
9.4 In practice, you will usually either expressly agree in advance to our use of your personal
information for marketing purposes, or we will provide you with an opportunity to opt out of
the use of your personal information for marketing purposes.
9.5 In this section, 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.
9.6 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(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.
9.7 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
9.8 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
9.9 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; the processing is for direct marketing purposes; and
the personal data have been unlawfully processed. However, there are certain general
exclusions of the right to erasure. Those 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.
9.10 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.
9.11 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.
9.12 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.
9.13 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.
9.14 To the extent that the legal basis for our processing of your personal data is consent,
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
9.15 If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint. Please write, in the first
instance, to Flat 9 Vanbrugh House, Loddiges Road, London, E9 7NP.
9.16 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.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices
of third parties.
11. Personal data of children
11.1 Our website and services are targeted at persons over the age of 18.
11.2 If we have reason to believe that we hold personal data of a person under that age in
our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be
corrected or updated.
13. About cookies
13.1 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.
13.2 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.
13.3 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.
14. Cookies that we use
navigate our website;
personalise our website for you;
accounts, including preventing fraudulent use of login credentials, and to protect our website
and services generally;
and services and
cookies more generally.
15. Cookies used by our service providers
when you visit our website.
15.2 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
available at: https://www.google.com/policies/privacy/.
16. Managing cookies
16.1 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);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
okies (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).
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17. Our details
17.1 This website is owned and operated by Chloesha Ellen Designs.
17.2 You can contact us:
(a) using our website contact form; or
(b) by email, using the email address published on our website.