1.1 SerendipiDi is committed to safeguarding the privacy of the visitors of its website www.serendipidi.com (“Website”).
2. HOW WE USE YOUR PERSONAL DATA
2.1 This Subsection covers:
(a) the general categories of personal data that SerendipiDi may process;
(b) the purposes for which SerendipiDi may process personal data; and
(c) the legal bases of the processing.
2.2 SerendipiDi may process data about your use of the Website (“Usage Data”). This Usage Data may be processed for the purposes of analysing the use of the Website. The source of the Usage Data is Google Analytics. The legal basis for this processing is SerendipiDi’s legitimate interests, namely monitoring and improving the Website. The Usage Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use..
2.3 We may process your personal data that is provided as part of an enquiry about SerendipiDi’s services (“Enquiry Data”). The Enquiry Data may include your name, contact telephone number and email address, for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent, namely taking steps, at your request, to provide information about our availability and services.
2.4 SerendipiDi may process your personal data that is provided in the course of the use of SerendipiDi’s services (“Service Data”). The Service Data may include your name, contact telephone number and email address. The Service Data may be processed for the purposes of providing SerendipiDi’s services, maintaining back-ups of SerendipiDi’s databases and communicating with you. The legal basis for this processing is the performance of a contract between you and SerendipiDi and/or taking steps, at your request, to enter into such a contract.
2.5 SerendipiDi may process information that you provide for publication on the Website or social media (“Publication Data”). The Publication Data may be processed for the purposes of enabling such publication and marketing thr Website. The legal basis for this processing is consent.
2.6 SerendipiDi may process information relating to its customer relationships, including customer contact information (“Customer Relationship Data”). The Customer Relationship Data may include your name, your contact details, and information contained in communications between SerendipiDi and you. The Customer Relationship Data may be processed for the purposes of managing SerendipiDi’s relationships with customers, communicating with customers, keeping records of those communications and promoting SerendipiDi’s products and services to customers. The legal basis for this processing is consent.
2.7 SerendipiDi may process information relating to transactions, including purchases of goods and services, that you enter into with SerendipiDi. (“Transaction Data”). The Transaction Data may include your contact details and the transaction details. The Transaction Data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and SerendipiDi and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of the Website and business.
2.8 SerendipiDi may process information contained in or relating to any communication that you send to SerendipiDi (“Correspondence Data”). The Correspondence Data may include the communication content and metadata associated with the communication. The Website will generate the metadata associated with communications made using the website contact forms. The Correspondence Data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is SerendipiDi’s legitimate interests, namely the proper administration of the Website and business and communications with users.
2.10 SerendipiDi may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is SerendipiDi legitimate interests, namely the proper protection of SerendipiDi’s business against risks.
2.11 In addition to the specific purposes for which SerendipiDi may process your personal data set out in this Subsection 2, SerendipiDi may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which SerendipiDi is subject, or in order to protect your vital interests or the vital interests of another natural person.
2.12 Please do not supply any other person’s personal data to SerendipiDi, unless we request you to do so.
3. PROVIDING YOUR PERSONAL DATA TO OTHERS
3.1 SerendipiDi may disclose your personal data to its insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.
3.2 SerendipiDi may disclose your contact details to SerendipiDi suppliers or subcontractors insofar as reasonably necessary to deliver sub-contracted services or product orders. The legal basis for this processing is consent.
3.3 In addition to the specific disclosures of personal data set out in this subsection 3, SerendipiDi may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which SerendipiDi is subject, or in order to protect your vital interests or the vital interests of another natural person.
4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
4.1 SerendipiDi provides information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated in the USA.
4.3 Our workflow management company, Trello Inc, is based in the United States. Trello, Inc. also complies with the US-Swiss Safe Harbor Framework developed by the U.S. Department of Commerce in consultation with the Federal Data Protection and Information Commissioner of Switzerland and has certified that it adheres to the Safe Harbor Privacy Principles.
4.4 Other services we use may have data centres in the United States. The online transfer will be protected by appropriate safeguards.
5. RETAINING AND DELETING PERSONAL DATA
5.1 This Subsection 5 sets out SerendipiDi’s data retention policies and procedure, which are designed to help ensure that SerendipiDi complies with its legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that SerendipiDi processes for any purpose shall not be kept for longer than is necessary for that purpose.
5.3 SerendipiDi will retain your personal data as follows: (a) Invoices, contact and contract details will be retained for a maximum period of 6 years (statute of limitations) following final delivery of services; (b) Planning information, wedding details and customer notes will be kept for a minimum of one year and a maximum of two years.
5.4 Notwithstanding the other provisions of this Subsection 5, SerendipiDi may retain your personal data where such retention is necessary for compliance with a legal obligation to which SerendipiDi is subject, or in order to protect your vital interests or the vital interests of another natural person.
7. YOUR RIGHTS
7.1 Summarised in this Subsection 7 are the rights that you have under GDPR. For a full explanation of these rights, please refer to the relevant law texts and guidance from the regulatory authorities.
7.2 Your principal rights under GDPR are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where SerendipiDi does, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, SerendipiDi will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request your personal data by contacting SerendipiDi.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, SerendipiDi may continue to store your personal data. However, SerendipiDi will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to SerendipiDi’s processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in SerendipiDi; or the purposes of the legitimate interests pursued by SerendipiDi or by a third party. If you make such an objection, SerendipiDi will cease to process the personal information unless SerendipiDi can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to SerendipiDi’s processing of your personal data for direct marketing purposes including profiling for direct marketing purposes. If you make such an objection, SerendipiDi will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for SerendipiDi’s processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from SerendipiDi in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that SerendipiDi’s processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for SerendipiDi’s processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to SerendipiDi.
8. LINKS TO OTHER WEBSITES
SerendipiDi is not responsible for the information handling practices of third party sites or services.
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10. COOKIES THAT WE USE
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