• 1. Introduction

     1. I respect your privacy and am committed to protecting your personal data. 

     2. This Privacy Policy explains how I handle your data when you:

        1. visit my website at colinwinter@icloud.com, or any associated sites or pages (the “Site”); or

        2. engage with me in respect of the products (my “Products”) or services  (my “Services”) that I provide;

        3. register on my mailing list.

  2. How I collect personal information

     1. Directly: I may collect personal information from you in the course of my business, including through the use my Site, when you contact or request information from me, when you engage my Services, or buy my products.

     2. Automatically: I may collect personal information from you by monitoring your use of, and interactions with, my Site and other electronic services and any electronic marketing I may send you.

  3. The types of personal information I collect

     1. The type of information I collect depends on my relationship to you and the context in which I obtain and process your personal data. A non-exhaustive list of the data I may collect and process is as follows:

        1. contact information such as name, addresses (postal and email), telephone and fax numbers;

        2. payment information, including bank account details;

        3. other information relevant to the provision of my Services or the supply of my Products.

  4. The basis on which I process your personal information

I will only use your personal data when the law allows me to. The legal grounds I rely on for processing your data depend upon the nature of my relationship with you and the context of processing and are as follows:

• 1. 1. 1. Contract Performance: where the processing is necessary for the performance of a contract with you, or to take steps prior to entering into a contract with you.

        2. Legal Obligation: where the processing is necessary for compliance with mandatory legal obligations to which I am subject; or

        3. Legitimate Interests: where the processing is necessary for the purposes of my legitimate business interests, except where those interests are overridden by the interests, rights or freedoms of affected individuals.

        4. Consent: where sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting me.

  2. What I do with your personal information

     1. I use the personal information I collect for the following purposes:

To provide my Services and Products to you – to administer and perform my Services or supply my Products, including to carry out my obligations arising from any agreements entered into between you and me, to contact you by email, phone, fax or post. 

Legal grounds: Contract Performance, Legitimate Interests (to enable me to perform my obligations and provide Products and Services to you), Consent. 

To maintain and develop my relationship with you in respect of my Services and Products – to provide you with details of my Services or Products and information about events with which I or my colleagues or musical/artistic associates are involved.

Legal grounds: Contract Performance, Legitimate Interests (to allow me to develop my business with you), Consent.

To ensure that I am paid - to recover payments due to me and to enforce such recovery. 

Legal grounds: Contract Performance, Legitimate Interests (to ensure that I am paid for my services).

To inform you of changes – to notify you about changes to my Products or Services, terms of business or privacy notice etc. 

Legal grounds: Legitimate Interest (to ensure that I can notify you about changes to my business), Consent

To re-organise or make changes to my business – to transfer your personal data in the event of a reorganisation of my business

Legal grounds: Legitimate Interest

• 1. Sharing your personal information 

I will not share your personal information with third parties without your written consent.  

• 1. How long I keep your personal information

     1. I will only retain your personal information for as long as is reasonably necessary for the purpose for which it was obtained and any other permitted linked purpose (for example satisfying any legal, regulatory, tax, accounting or reporting requirements).

     2. To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

  2. Protecting your data

     1. I take reasonable measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

  3. Where your personal information will be processed

     1. My data processing takes place within the EEA. 

  4. How to access your information and your other rights

     1. This section sets out the rights that you have in connection with my processing of your personal information. You will not have to pay a fee to exercise any of the rights detailed in this section, however I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

     2. I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.

     3. Right of Access

You have the right to request details of personal information which I hold about you. If you would like a copy of your personal information, please write to me. If you require additional copies of any data I hold about you then I may need to charge a reasonable fee.

• 1. 1. Right to Rectification

You have the right to ask me to correct any incorrect information I hold about you, or to complete any incomplete information. If you think that any information I have about you is incorrect, incomplete or needs updating then please contact me. 

• 1. 1. Right to Erasure

This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• 1. 1. Right to Restrict Processing

You have the right to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data's accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

• 1. 1. Right to Data Portability

You have the right, in certain circumstances, to obtain personal information you've provided me with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask me to transfer this to a third party of your choice.

• 1. 1. Right to Object

Where I am relying on a legitimate interest (or those of a third party) as my lawful ground for processing your personal data, and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to object to his processing. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

• 1. 1. Right to Withdraw Consent

Where I am relying on consent to process your personal data, you may withdraw your consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide Products or Services to you. I will advise you if this is the case at the time you withdraw your consent.

• 1. 1. In addition to the above you have the right to be notified of a personal data breach if it results in a high risk to your rights and freedoms.

  2. Contact and Further Information

     1. If you have any queries or requests regarding this notice, or my practices concerning your personal data, please contact me by email at colinwinter@icloud.com or telephone on 07771 768220.

     2. I will take reasonable steps to resolve or answer concerns as soon as possible and normally within 30 days.

     3. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.