PRIVACY AND COOKIES POLICY
I take the privacy of your information very seriously, and will never sell any data I collect.
This privacy policy applies between you, the User of this Website, and Saskia von Diest, the owner of this Website.
This privacy policy applies to my use of any and all data collected by me, or provided by you, in relation to your use of the Website.
Please read this privacy policy carefully.
Definitions and interpretation
1. In this privacy policy, the following definitions are used:
1.1. User or You - any third party that accesses the Website and is not either (i) employed by me and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to me and accessing the Website in connection with the provision of such services.
1.2. Website - the website that you are currently using, https://www.ecofluency.org, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
1.3. Ecofluency - the name of the business founded and run by Saskia von Diest, providing educational, facilitation, consulting and research advisory services.
1.4 Data - collectively all information that you submit to me via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.
1.5. Data Protection Laws - any applicable law relating to the processing of personal data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK.
2. In this privacy policy, unless the context requires a different interpretation:
2.1. the singular includes the plural and vice versa;
2.2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
2.3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
2.4. “including” is understood to mean “including without limitation”;
2.5. reference to any statutory provision includes any modification or amendment of it;
2.6. the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy
3. This privacy policy applies only to the actions of Saskia von Diest and Users with respect to this Website. It does not extend to the Website host, or any websites that can be accessed from this Website including, but not limited to, any links I may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, I am the “data controller”. This means that I determine the purposes for which, and the manner in which, your data is processed.
What Ecofluency Does
5. Ecofluency is a business that provides educational, facilitation, consulting and research advisory services to clients.
The focus is on supporting other humans to develop the innate ability that they have to communicate with the rest of other-than-human Nature, and to support others who do similar work.
Data collected
6. I may collect the following data, including personal data, from you:
6.1. name;
6.2. contact information such as email addresses and telephone numbers;
6.3. information provided on contact form(s);
6.4. information provided to make purchases;
6.5. details of contact I have had with you such as referrals and appointment requests
in each case, in accordance with this privacy policy.
If I hold this information, I use it in order to provide you with the service(s) stated above. This means that the legal basis of my holding your personal data is for legitimate interest.
I retain your contact information indefinitely. Any additional personal data is retained for up to 6 months maximum, after which it is deleted from my records.
How I collect Data
7. I collect data in the following ways:
7.1. data given to me by you;
7.2. data received from other sources; and
7.3. data collected automatically.
Data given to me by you
8. I will collect your data in a number of ways, for example:
8.1. when you contact me through the Website, by telephone, post, e-mail or through any other means;
8.2. through completing an intake form or during a consultation
8.3. through signing and agreeing to Terms and Conditions
8.4. when you complete surveys that I use for research purposes (although you are not obliged to respond to them);
8.5. when you make payments to us, through this Website or otherwise;
8.6. when you elect to receive marketing communications from us;
8.7. when you use my services;
8.8. when you enter a competition or promotion through a social media channel;
8.9. other third party services specified via Website;
in each case, in accordance with this privacy policy.
Data received from other sources
9. I may receive data about you from the following publicly available third party sources:
9.1. Facebook
9.2. Instagram
9.3. Twitter
in each case, in accordance with this privacy policy.
Data collected automatically
10. To the extent that you access the Website, I will collect your data automatically, for example:
10.1. about your visit to the Website - this information helps me to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
10.2. via cookies, in line with the cookie settings on your browser. For more information about cookies, and how they are used on the Website, see the section below, headed “Cookies”.
Use of Data
11. Any or all of the above data may be required by me from time to time in order to provide you with the best possible service and experience when using this Website. Specifically, Data may be used by me for the following reasons:
11.1. internal record keeping;
11.2. improvement of my products / services;
11.3. transmission by email of marketing materials that may be of interest to you;
11.4. contact for market research purposes which may be done using email, telephone or mail. Such information may be used to customise or update the Website;
in each case, in accordance with this privacy policy.
12. I may use your Data for the above purposes, if I deem it necessary to do so for my legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
13. For the delivery of direct marketing to you via e-mail, I’ll need your consent, whether via an opt-in or soft-opt-in:
13.1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with me (for example, you contact me to ask for more details about a particular product/service, and I am marketing similar products/services). Under “soft opt-in” consent, I will take your consent as given unless you opt-out.
13.2. for other types of e-marketing, I am required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that I’ll provide.
13.3. if you are not satisfied about my approach to marketing, you have the right to contact me about it for feedback, or withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
14. When you register with Ecofluency and set up an account to receive my services, the legal basis for this processing is the performance of a contract between you and me and/or taking steps, at your request, to enter into such a contract.
Sharing data
15. I may share your Data with the following groups of people for the following reasons:
15.1. employees, agents and/or professional advisors, to obtain advice
15.2. third party service providers who provide services to me which require the processing of personal data – to help third party service providers in receipt of any shared data to perform functions on my behalf to help ensure the Website runs smoothly;
15.3. third party payment providers who process payments made over the Website – to enable third party payment providers to process user payments and refunds;
15.4. relevant authorities – to facilitate the detection of crime or the collection of taxes or duties to fulfil duty of care;
16. I will keep information about you confidential, and will only disclose your information with other third parties with your express consent, with the exception of the following categories of third parties:
16.1. Any contractors and advisors that provide a service to me or act as my agents on the understanding that they keep the information confidential
16.2. Anyone to whom I may transfer my rights and duties under any agreement I have with you.
16.3. Any legal or crime prevention agencies and/or to satisfy any regulatory request, if I have a duty to do so.
17. I may share your case history in an anonymised form with my peers for the purpose of professional development only. This may be at supervision meetings, conferences, online forums, and through publishing in scientific journals, trade magazines or online professional sites. I will always seek your explicit consent before I would discuss your case anonymously or process your data this way.
in each case, in accordance with this privacy policy.
Keeping data secure
18. I will use technical and organisational measures to safeguard your data, for example:
18.1. I only use information that may identify you in accordance with GDPR (the General Data Protection Regulation (EU) 2016/679). This requires the processing of personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
18.2. I follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing you with a service. I will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.
19. I also ensure the information I hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). I ensure external data processors that support me are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
20. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse, loss or unauthorised access to your data, please let me know immediately by contacting me via this e-mail address: saskia(at)ecofluency(dot)org.
21. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org.
Data retention
22. All records held by the me will be kept for the duration of 6 months or until you request that the data be deleted.
23. Even if I delete your data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Your rights
24. You have the following rights in relation to your data:
24.1. Right to access – the right to request (i) copies of the information I hold about you at any time, or (ii) that I modify, update or delete such information. If I provide you with access to the information I hold about you, I will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where I am legally permitted to do so, I may refuse your request. If I refuse your request, I will tell you the reasons why.
24.2. Right to correct – the right to have your data rectified if it is inaccurate or incomplete.
24.3. Right to erase – the right to request that I delete or remove your data from my systems.
24.4. Right to restrict my use of your data – the right to “block” me from using your data or limit the way in which I can use it.
24.5. Right to data portability – the right to request that I move, copy or transfer your data.
24.6. Right to object – the right to object to my use of your data including where I use it for legitimate interests.
25. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is my legal basis for processing your Data), please contact me via this e-mail address: saskia(at)ecofluency(dot)org
26. If you are not satisfied with the way a complaint you make in relation to your Data is handled by me, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk.
27. It is important that the data I hold about you is accurate and current. Please keep me informed if your data changes during the period for which I hold it.
28. If you want to access your data you must make a subject access request in writing to saskia(at)ecofluency(dot)org. Under special circumstances, some information may be withheld. I shall respond within 20 working days from the point of receiving the request and all necessary information from you. My response will include the details of the personal data I hold on you including:
28.1. Sources from which I acquired the information
28.2. The purposes of processing the information
28.3. Entities with whom I am sharing the information
29. You have the right, subject to exemptions, to ask to:
29.1. Have your information deleted.
29.2. Have your information corrected or updated where it is no longer accurate.
29.3. Ask me to stop processing information about you where I am not required to do so by law.
29.4. Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from me.
29.5. Object at any time to the processing of personal data concerning you.
29.6. I do not carry out any automated processing, which may lead to automated decision based on your personal data.
29.7. If you would like to invoke any of the above rights then please email saskia(at)ecofluency(dot)org.
Transfers outside the European Economic Area
30. Data which I collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if my servers are located in a country outside the EEA or one of my service providers is situated in a country outside the EEA.
31. I will only transfer data outside the EEA where it is compliant with data protection legislation, and the means of transfer provides adequate safeguards in relation to your data.
32. To ensure that your data receives an adequate level of protection, I have put in place appropriate safeguards and procedures with the third parties I share your data with. This ensures your data is treated by those third parties in a way that is consistent with the Data Protection Laws.
Links to other websites
33. This Website may, from time to time, provide links to other websites. I have no control over such websites and am not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
Changes of business ownership and control
34. I may, from time to time, expand or reduce my business and this may involve the sale and/or the transfer of control of all or part of it. Data provided by Users will, where it is relevant to any part of my business, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the data for the purposes for which it was originally supplied to me. In this instance, I will take steps with the aim of ensuring your privacy is protected.
Data that the Website host uses
35. This Website is hosted by Squarespace, and collects personal data needed to run this Website, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalised form. This data includes:
35.1. Information about your browser, network, and device
35.2. Web pages you visited prior to coming to this Website
35.3. Your IP address
36. This information may also include details about your use of this Website, including:
36.1. Clicks
36.2. Internal links
36.3. Pages visited
36.4. Scrolling
36.5. Searches
36.6. Timestamps
37. You can read about how Squarespace stores your data here.
Cookies
38. This Website also uses cookies (and similar technologies - pixels, tags, local storage, and device fingerprinting) through Squarespace, which are small files or pieces of text that download to a device when a visitor accesses a website or app. These cookies:
38.1. Enable the Website to: function efficiently
38.2. Personalise content
38.3. Permit online behavioural target advertising (unfortunately, I can’t disable these on my side)
39. For information about viewing the cookies dropped on your device, visit the cookies Squarespace uses.
39.1.These functional and required cookies are always used, which allow Squarespace, the hosting platform, to securely serve this Website to you.
39.2 These analytics and performance cookies are used on this site when you acknowledge the cookie banner. Analytics cookies are used to view site traffic, activity, and other data.
40. Before the Website places cookies on your computer, you will be presented with a message bar informing you of those Cookies. By using this Website, you are giving your consent to the placing of Cookies, and are enabling me to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
41. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
42. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
43. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
44. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
General
45. You may not transfer any of your rights under this privacy policy to any other person. I may transfer my rights under this privacy policy where I reasonably believe your rights will not be affected.
46. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
47. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
48. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Changes to this privacy policy
49. I reserve the right to change this privacy policy as I may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact me by email at saskia(at)ecofluency(dot)org.
17 January 2024