Creativity For Growth & Business Inc Privacy Notice

1. Privacy notice

1. Who are we?

Creativity For Growth And Business Inc is an organisation whose aim is to bring music back into the commercial and non commercial sectors of the economy.

Our GDPR Owner and data protection representatives can be contacted directly here:

• (colin@celticfiddleguru.com)

The personal data we would like to collect from you is:

The personal data we collect/ process will be used for the following purposes:

• Emailing newsletters and to provide an update of events and products which we think will be of interest to you. It’s up to you to decide whether or not you want to receive this information.
• Provide and deliver the products and services you request, process transactions and send you transaction-related information, including confirmations and invoices
• Respond to your comments, questions and requests and provide customer service
• Contacting you for reasons related to the service you have signed up for e.g. course progress, discovery call
• To contact you about a submission you have made to the website, including any content you provide.
• IP addresses are used to identify the location of users, the number of visits from different countries
• To analyse and improve the services offered on www.celticfiddleguru.com e.g. user friendly navigation experience and to administer the website.
• To enable the review, development and improvement of products, services and special offers online.
• To communicate with you in general
• To audit and administer our accounts
• To process donations
• To keep registration lists and emergency contact information for participants at our workshops, other events and retreats
• To satisfy legal and regulatory obligations and for the prevention of fraud or misuse of services.
• For the establishment, defence and/ or enforcement of legal claims.

Our legal basis for processing for the personal data:

• Performance of a contract: When you make a purchase from us or make a donation, you are entering into a contract with us.  We need to process and store your data to perform this contract. For example, we may need to contact you by email or telephone in the case of an event cancellation or if there is a problem with your payment.
• Legitimate interest: We collect and process your personal information for purposes that are in our legitimate business interest. However, we only do this if there is no overriding prejudice to you by using your personal information in this way.
• Explicit consent: For any situations where the two bases above are not appropriate, we will instead ask you for your explicit consent before using your personal information in that specific situation.
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Any legitimate interests pursued by us, or third parties we use, are as follows:

• Direct Marketing: Creativity For Growth and Business Inc wishes to communicate with you about the work we do and services we offer in ways that you find relevant, timely and respectful. To do this, we use the data we have stored about you such as the events you have attended in the past, aswell as any preferences you make have told us about. For email, we will give you the opportunity to opt out of receiving further emails during your first registration with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send to you. Alternatively, you can use the contact details at the end of this policy.

2. Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Creativity For Growth And Business Inc to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by giving you the opportunity to opt out of receiving further emails during your first registration with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send to you. Alternatively, you can use the contact details at the end of this policy.

3. Disclosure

Creativity For Growth And Business Inc  will not pass on your personal data to third parties without first obtaining your consent. These third-party suppliers support our day to day operations e.g. in the areas of website hosting, online file storage and email delivery. We may also hire third parties to operate, maintain or improve our website and other digital services. Some of these service providers will by necessity have access to or be directly involved in processing or storing a subset of the personal information you share with us. All our third-party data processors have been carefully chosen as service suppliers who also practice responsible data handling. We believe that each has in place appropriate protections to ensure the security of the data we store or process with them and have clear policies for how they treat that data. But if in doubt, you should review their individual Privacy Policies. The following third parties will receive your personal data for the following purposes as part of the processing activities.

4. Retention period

Creativity For Growth and Business Inc will process personal data and will store the personal data for as long as is legally or practically necessary for our business. We will retain your data for as long as you choose to stay subscribed or  such time as we consider your account to be in-active i.e. you are no longer opening or engaging with our emails.

5. Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access - you have the right to request a copy of the information that we hold about you.
• Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing - where certain conditions apply to have a right to restrict the processing.
• Right of portability - you have the right to have the data we hold about you transferred to another organisation.
• Right to object - you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling - you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

6. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Creativity for Growth And Business Inc (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Creativity For Growth and Business Inc data protection representatives [Data Protection Officer (DPO)] / [GDPR Owner].

The details for each of these contacts are:

7. Privacy statement

Read more about how and why we use your data below.

4. Online privacy statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

How we use your information

This privacy notice tells you how we, Creativity For Growth And Business Inc, will collect and use your personal data for example for  general browsing, cookies, improving online courses, email marketing, registering to attend an online or offline event, emailing Creativity For Growth And Business Inc

General Browsing: Our website is hosted by Bandzoogle. When you access the website, your computer’s IP address is a unique identifier and is stored along with information about your operating system, browser version and the pages/files you access.

Google Analytics, the standard version is also used to gain a better understanding of how the website is being discovered and interacted with. This information is used to help improve the visitor experience and also where next to develop the website. The information presented is in aggregate form about the geographic location, device types and operating systems.

Cookies: Cookies are small text files that are automatically placed onto your device when you visit our website. This means that a website will remember you and enable online transactions. We use cookies to help us make our site  and the way you might use it  a better experience for you. It also helps us understand how you use our website, where we can make improvements and how best to tell our audiences about events they might be interested in.

Improving Online Courses: We want our clients to gain the most out of participation in our online courses and will monitor the progression through the courses e.g. time taken to complete course sections to ensure that we respond in a timely manner to maintain the momentum of taking the courses.

Email Marketing: We use Active Campaign as our email service provider. This allows us to communicate with our customers in a timely, efficient and relevant manner. The opt ins can take place for example on the website or at an offline or online event. The name and email address which is submitted is held securely by Active Campaign. Active Campaign is a very well established and respected email service provider. The double opt in process of confirmation is used to confirm that those people who would really like and consent to receive email updates do so. Once a link in the sent email is clicked, the user is confirmed as an opt in to receive further emails. Active Campaign will collect the user’s IP address, type of operating system and device plus a timestamp. All this provides evidence of consent to the Regulator should this ever be requested. The information will be retained with Active Campaign for as long as the customer chooses to stay subscribed or the account is no longer opening or engaging with emails. At the bottom of each email there is an Unsubscribe button which can be used to unsubscribe from the emailing list. We will also capture your interactions with our emails and website for example, the links clicked within an email or pages visited on the website. This is done using cookies and helps to improve the user experience.

Registering To Attend An Online Or Offline Event: When registering for an online or offline event, Creativity For Growth And Business Inc will use a number of different service providers to record your registration details e.g. Name, email address, telephone number, address. The service provider used will depend on whether the event is online or offline. For online, a combination of Lead Pages, Zoom Conference Calls and Active Campaign Email Service Provider is used. Your details will then be used to check if you attended the actual event and to send you email updates after the event regarding any relevant information. This could be with details of future similar events and to help shape future online events. For an offline event, the combination of service providers could be Eventbrite and Active Campaign. Again, the registrant’s details will recorded via a form e.g. name, email address, telephone number, country. The details will help to provide relevant communication before, during and after the event and also future email communications. The information will be retained for as long as the customer chooses to stay subscribed or the account is no longer opening or engaging with emails. At the bottom of each email there is an Unsubscribe button which can be used to unsubscribe from the emailing list.

Emailing Creativity For Growth And Business  Inc: When you send us an email, Creativity For Growth And Business Inc will collect your email address and any other information you provide within your email. Any emails you send us will be stored on Google servers. Therefore your email and any associated personal data may be transferred outside of the European Economic Area to servers located in the USA. The information you provide will only be processed in relation to the purpose of your correspondence with us. We have no fixed retention period for email correspondence, but we are committed to only storing your data for no longer than is necessary to serve our legitimate interests of record keeping or to perform a contract we have entered into with you

Why does Creativity For Growth And Business Inc need to collect and store personal data?

In order for us to provide you with information and event updates, we need to collect personal data for correspondence purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes Creativity For Growth And Business Inc would contact you for additional consent.

Will Creativity For Growth And Business Inc share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Creativity For Growth And Business Inc in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to  fulfil the service they provide you on our behalf, for example, email communication, online course platform. When they no longer need your data to fulfil this service, they will dispose of the details in line with Creativity For Growth And Business Inc’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Creativity For Growth And Business Inc use the personal data it collects about me?

Creativity For Growth And Business Inc will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Creativity For Growth And Business Inc is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Creativity For Growth And Business Inc contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

Creativity For Growth And Business Inc at your request, can confirm what information we hold about you and how it is processed. If Creativity For Growth And Business Inc does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Creativity For Growth And Business Inc or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Creativity For Growth And Business Inc accepts the following forms of ID when information on your personal data is requested: Passport, driving licence, birth certificate, utility bill (from last three months)

Contact details of the [Data Protection Officer (DPO)] / [GDPR Owner]: