This is the Privacy Notice of Anywayward.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how data protection law protects you.
This privacy notice is set out as below:
1. WHO WE ARE AND IMPORTANT INFORMATION
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. COOKIE POLICY
6. WHO WE SHARE YOUR PERSONAL DATA WITH
7. INTERNATIONAL TRANSFERS
8. DATA SECURITY
9. DATA RETENTION
10. YOUR LEGAL RIGHTS
11. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
12. QUERIES, REQUESTS OR CONCERNS
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, download an opt-in, purchase a product, join a course or programme, take part in a competition, complete a survey, post on our social media channels, website or blog, or contact us via our website, social media channels, phone, email or otherwise or in connection with other activities, services, features, or resources we make available on our website.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data controller(s)
Anywayward is the controller and responsible for your personal data (collectively referred to as Anywayward, “we”, “us” or “our” in this privacy notice). For all data matters you can contact Rachel via email at Rachel@anywayward.com or write to us at 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, W1T 6EB.
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which includes, but is not limited to, the data we have grouped together as follows:
- Identity Data includes first name, last name, username, marital status, title, date of birth, gender.
- Contact Data includes your billing address, delivery address, email address, phone numbers.
- Technical Data includes data about how you use our website, IP address, your login data, details about your browser, length of visit to pages on our website, page views, navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website
- Financial Data includes your financial details, bank account/payment details, credit card information from third parties
- Transaction Data includes details about payments to and from customers/other details of products customers have purchased
- Profile Data includes usernames, purchases and/or orders made, user/customer preferences/feedback
- Usage Data includes information about how the user uses the website, products and services
- Marketing and Communications Data marketing and communication preferences
- Other Data includes your any personal data you post on our website, any other information you directly provide to us whether through our contact form, over the phone, by email or otherwise, photographs that you submit, resumes.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:
- You sign up to our newsletter or mailing list,
- You download an opt-in
- You purchase a product from our website
- You join a course or programme
- You contact us for information via our website or social media channels, by phone or email
- You work with us
- You respond to a survey
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as analytics providers such as Google based outside the UK, advertising networks such as Facebook based outside the UK, search information providers such as Google based outside the UK, providers of technical, payment and delivery services, fraud detection agencies and data brokers or aggregators. We may also receive data from publicly available source such as Companies House and the Electoral Register (or their equivalents) based inside or outside of the UK.
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 anonymized 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.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by [INSERT DETAILS].
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at rachel@anywayward.com.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via email at rachel@anywayward.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Other | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, obtaining and maintaining insurance policies, and obtain professional advice) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party use of personal information
We may share your information with third parties when you explicitly authorise us to share your information. Additionally, we may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies.
We currently use the following third-party service providers:
Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. We use Google Analytics to provide the best user experience and service to you and to evaluate and improve our site. Google Analytics also improves our visibility and monitors website browser behaviour and navigation across our site.
Google Analytics collect this information on our behalf in accordance with our instructions and in line with their own privacy policies. They may collect the following data about the way you use our site, which will almost always be anonymised and aggregated before reporting back to us:
- Number of visitors to our site
- Pages visited whilst using the site and time spent per page
- Page interaction information, such as scrolling, clicks and browsing methods
- Source location and details about where users go when they leave the site
- Page response times and any download errors
- Other technical information relating to end user device, such as IP address or browser plug-in
From time to time we may use the information collected about you to present you with targeted advertisements using platforms such as Facebook, Twitter, Google and/or Instagram.
Flodesk – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications that you have opted-in to receive. Please refer to Flodesk’s privacy policy for further information.
Bluehost – this service is responsible for hosting and operating the website platform Anywayward uses.
Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
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 tracking your interaction with the embedded content if you have an account and are logged in to that website.
Opting out
We will make it as easy as we can for you to opt out of unwanted processing providing it does not restrict our ability to provide you with the primary service you have requested.
You can ask us or third parties to stop sending you marketing messages at any time by emailing rachel@anywayward.com or by clicking the unsubscribe buttons on the bottom of all our marketing emails. It may take 24 hours for this to become effective.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of other transactions, such as purchases, warranty registrations, etc.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at rachel@anywayward.com .
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. COOKIE POLICY
INFORMATION ABOUT OUR USE OF COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. - Analytical/performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. - Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). - Targeting cookies
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Our Site uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customises Site content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein.
We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.
The Site may engage in affiliate marketing, which is done by embedding tracking links into the Site. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control and we cannot accept any liability for the third party’s compliance with its legal obligations. These cookies are likely to be analytical/performance cookies or targeting cookies.
Advertising cookies can be de-activated by visiting the consumer page to manage the use of these types of cookies.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
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.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Government bodies that require us to report processing activities or otherwise disclose your personal data.
- Market researchers and fraud prevention agencies.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. These third parties will collect data in line with their own privacy policies.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by implementing safeguards:
- We may transfer your personal data to countries that the United Kingdom authorities have approved as providing an adequate level of protection for personal data by; or
- If we use US-based providers that are part of a privacy framework (such as the successor to the US Privacy Shield), we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the United Kingdom authorities which give personal data the same protection it has in the UK
Please contact us via email at rachel@anywayward.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize 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.
10. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact us via email at rachel@anywayward.com .
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Changes to this notice and your duty to inform us of changes
We continually review our privacy practices and may change this policy from time to time.
This version of our privacy notice was published on 19/11/2023 and historic versions can be obtained by contacting us via email at rachel@anywayward.com.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
12. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us via email at rachel@anywayward.com.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.
