This privacy policy sets out how Gwyn Wansbrough uses and protects any information that you volunteer when you use this website.
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
We can be reached via e-mail at gwyn@gwynwansbrough.com
Mailing Address:
Gwyn Wansbrough
This Privacy Policy explains how information about you is collected, used and disclosed by Gwyn Wansbrough (“Company,” “we,” “us” or “our”). This Privacy Policy applies to information we collect when you use our websites, such as www.gwynwansbrough.com, our mobile applications and the services, content and materials made available through our websites or mobile applications (collectively, the “Services”), or when you otherwise interact with us.
By accessing or using the Services, you agree to this Privacy Policy, including the collection, use and sharing of your information as described herein. If you do not agree with our Privacy Policy, you must not access or use the Services. This Privacy Policy does not apply to information collected by us offline or through any other means, or by any other website, app or third party, including through any application or content that may link to or be accessible from the Services.
The Important Stuff: We will not sell, distribute or lease your personal information to third parties unless we have your explicit permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
More Important Stuff: If you believe that any information we are holding about you is incorrect, incomplete or wish for it to be deleted, please write to or email us as soon as possible, at the above address or email address. We will promptly correct any information found to be incorrect or remove any information you request to be deleted.
You have the right to access the personal data we hold about you, request corrections, deletion, or restrictions on its processing, and object to certain processing activities. To exercise these rights, contact us at gwyn@gwynwansbrough.com. You also have the right to lodge a complaint with your local data protection authority. If you are not satisfied with how we process your personal data, you can contact the Spanish Data Protection Authority (AEPD) at www.aepd.es.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date at the top of this policy and, in some cases, we may provide you with additional notice (such as by adding a statement to our website or by sending you a notification). We encourage you to review our Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.
Collection of Information
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, subscribe to a newsletter or email list, participate in an event, survey, contest or promotion, make a purchase, communicate with us via third-party social media sites, request customer support or otherwise communicate with us.
The types of information we may collect include your:
- Name
- Email address
- Password
- Postal address
- Phone number
- Occupation
- Employer information
- Photo
- Securely stored payment information (such as your credit or debit card and billing address)
- Preference or interest data
- Information you provide when you contact customer support or report a problem with the Services, including your email address, and records and copies of such correspondence
- Any other information you choose to provide.
We process personal data under the following legal bases: your consent, to fulfill contracts, or for legitimate business interests. We rely on Standard Contractual Clauses approved by the European Commission to safeguard personal data transferred to the United States. Our Services are not directed at children under 13 (or 16 in the EU). We do not knowingly collect personal information from children.
If we transfer your personal data outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or transfers to countries deemed to provide adequate protection.
User Contributions: You also may provide information to be posted, submitted, published, displayed, or transmitted (“posted”) on public areas of the Services, or to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Automatically
When you access or use our Services, we automatically collect information about you, including:
Log Information: We collect log information about your use of the Services, including your Internet Protocol (“IP”) address, web request, access times, pages viewed, web browser, links clicked and the page you visited before navigating to the Services.
Mobile Device Information: We collect information about the mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, mobile network information and information about your use of our mobile applications.
Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Your Choices” below.
In the event of a data breach affecting personal data, we will notify affected users and relevant authorities within 72 hours, as required by law.
Information We Collect From Other Sources
We may also obtain information from other sources and combine that with information we collect through our Services. For example, if you create or log into your account through a third-party social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media site; we may also collect information about you when you post content to our pages/feeds on third-party social media sites.
Use of Information
We may use information about you for various purposes, including to:
- Provide, maintain, improve and promote our products and services;
- Provide and deliver the information, products and services you request, process transactions and send you related information, including confirmations and receipts;
- Send you technical notices, updates, security alerts, and support and administrative messages;
- Respond to your comments, questions and requests, and provide customer service;
- Communicate with you about products, services, surveys, offers, promotions, rewards and events offered by
- Company and others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage and activities in connection with our Services;
- Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
- Facilitate contests, sweepstakes and promotions, and process and deliver entries and rewards;
- Link or combine with information we get from others to help understand your needs and provide you with better service; and
- Carry out any other purpose for which the information was collected.
We are based in Spain, and the information we collect is governed by Spanish and European Union (EU) data protection laws, including the General Data Protection Regulation (GDPR). By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of your information within Spain, the European Economic Area (EEA), and to other countries, in accordance with this Privacy Policy and applicable laws.
Sharing of Information
We may share information about you as follows or as otherwise described in this Privacy Policy:
- With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
- When you participate in the interactive areas of our Services, certain information you provide may be displayed to other users, such as your name, photo, comments and other information you choose to provide;
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Company or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; and
- With your consent or at your direction.
We retain personal information for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law.
Third-Party Information
Third-Party Advertisers: Some content or applications on the Services are served by third parties, including advertisers, ad networks and servers, content providers and application providers. We may use your information to display advertisements to our advertisers’ target audiences. Though we do not disclose your personal information for these purposes, if you click on or otherwise interact with an advertisement, the advertiser may assume you meet its target criteria. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use the Services. We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Company and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity.
We do not control parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices.
Third-Party Providers: Further, we may work with third-party service providers to help improve our Services. When you interact with third-party providers, you may be providing information directly to the third party. For example, all online payments are processed through third-party payment processors, and you may communicate post information through third-party social media, or communicate with third parties regarding orders, transactions, updates or marketing relating to your use of the Services.
Some third-party providers we engage include:
Use of Information by Third Parties: We do not control third parties’ tracking technologies or how they may be used. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. Please note that when you use third-party services, their own terms of use and privacy policies will govern your use of their services. If you have any questions about such policies, you should contact the responsible provider directly.
Opting Out of Targeted Advertising, Sharing, and Sales
We process personal information to understand and improve your experience with our Services and to serve you targeted advertisements. Some of these activities may be considered "sales" or "sharing" of your personal information or "targeted advertising" under certain privacy laws. To opt out of preference-based advertising, please email us. Note, this will not stop you from seeing sponsorships or advertisements in our newsletters, but those ads will be selected randomly rather than based on your known preferences.
Social Sharing Features
The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Your Rights under the CCPA
This section only pertains to users based in California.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
- Disclosure of personal information we collect about you. You have the right to know:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom we share personal information, if any; and
- The specific pieces of personal information we have collected about you.
- Please note we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
- Provide the personal information to you more than twice in a 12-month period.
- Personal Information Sold or Used for a Business Purpose. In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
- The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
- The categories of personal information that we disclosed about you for a business purpose.
- Right to Deletion. Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records
- Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality; or
- Comply with an existing legal obligation.
- Protection Against Discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things.
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Your Rights under the CCPA
If you would like to exercise any of your rights as described in this Privacy Policy, please:
- Email us at gwyn@gwynwansbrough.com
- Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
- If you choose to contact directly email or in writing, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number);
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
- We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
Security
We, or through third-party service providers, have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the Internet is never completely secure. Although we reasonably try to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about providing information in public areas of the Services like messaging threads. The information you share in public areas may be viewed by any user of the Services.
Your Choices
Account Information
You may review, correct or modify information maintained in your online account at any time by logging into your account and updating your profile information or by emailing us at gwyn@gwynwansbrough.com. If you wish to delete or deactivate your account, please email us at gwyn@gwynwansbrough.com, but note that some information you provide through the Services may continue to be accessible (e.g., comments you submit through the Services) and that we may continue to store information about you as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability or functionality of our Services
Promotional Communications
You may opt out of receiving promotional communications from us by following the instructions in those communications or by sending an email to gwyn@gwynwansbrough.com. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
Contact Us
If you need this policy in an alternative format, or if you have any questions about this Privacy Policy, please contact us at gwyn@gwynwansbrough.com.
Last updated October 19, 2024