Introduction

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

Carlotta is pleased to provide the following Privacy Notice:

PERSONAL DATA

Carlotta uses the information collected from you to provide your requested organisational services. In you making initial contact you consent to Carlotta maintaining a dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services.

Any information Carlotta holds about you or your business encompasses all the details we hold about you and any organisational services records.

Carlotta will only collect the information needed so that it can provide you with organisational services.

In order to meet its contractual obligations, Carlotta utilises the following third parties:

When working with Carlotta, we will ensure that the organisation is fully GDPR compliant through contractual requirement.

LEGAL BASIS FOR PROCESSING PERSONAL DATA

• To meet Carlotta contractual obligations to clients and to also respond to marketing enquiries.
• Legitimate interests pursued by Carlotta and/or its clients

• To promote the marketing and consulting services offered by Carlotta and/or to market the services and/or products offered

CONSENT

Through agreeing to this privacy notice you are consenting to Carlotta processing your personal data for the purposes outlined.

You may withdraw consent at any time by emailing Michaeljpwright@gmail.com or writing to us, see last section of this document for full contact details.

DISCLOSURE

Carlotta may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Carlotta requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR.

Carlotta do not broker or pass on information gained from your engagement with the agency without your consent. However, Carlotta may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Bath Rugby, its clients and/or the wider community.

RETENTION POLICY

Carlotta will process personal data during the duration of any contract and will continue to store only the personal data needed for ten years after the contract has expired to meet any legal obligations.

Who we are

Our website address is: https://carlottapilotcutter.com.

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

When you submit a form, we will use this data to contact you regarding your enquiry. We will not add you to a mailing list or sell your data.

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.

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.

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.

DATA STORAGE

Data is held in within the EAA area only, be this on premise or cloud services

Your Rights as a Data Subject

At any point whilst Carlottais in possession of or processing your personal data, all data subjects have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing
• Right of portability – you have the right to have the data we hold about you transferred to another organisation
• Right to object – you have the right to object to certain types of processing such as direct marketing
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling

In the event that Carlotta refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

Carlotta, at your request, can confirm what information it holds about you and how it is processed.

You can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data
• Contact details of the Data Protection Champion, where applicable
• The purpose of the processing as well as the legal basis for processing
• If the processing is based on the legitimate interests of Carlotta or a third party such as one of its clients, information about those interests
• The categories of personal data collected, stored and processed
• Recipient(s) or categories of recipients that the data is/will be disclosed to
• How long the data will be stored
• Details of your rights to correct, erase, restrict or object to such processing
• Information about your right to withdraw consent at any time
• How to lodge a complaint with the supervisory authority (Data Protection Regulator)
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data
• The source of personal data if it wasn’t collected directly from you
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing
• To access what personal data is held, identification will be required

Data Subject Access Request Process and Policy

If you want us to supply you with a copy of any personal data we hold about you, please complete this form and send it the address below.

Carlotta will accept the following forms of ID when information on your personal data is requested:

• A copy of your national ID card
• Driving license, passport
• Birth certificate and a utility bill not older than three months

A minimum of one piece of photographic ID listed above and a supporting document is required.

If Carlotta is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to Michaeljpwright@gmail.com or writing to us at the address found at the end of this document.

Complaints

In the event that you wish to make a compliant about how your personal data is being processed by Carlotta or its partners, you have the right to complain to the Carlotta Data Protection Champion in the first instance, or the Carlotta owners as an escalation point. If you do not get a response within 30 days you can complain to the Data Protection Regulator.

RIGHTS TO BE FORGOTTEN AND RECTIFICATION

In the event that you wish to exercise your to erasure or rectification of the personal data being processed by Carlotta or its partners, you should contact the Data Protection Champion.

The details for each of these contacts are:

Michaeljpwright@gmail.com