Jane Ralls Dance Management Privacy policy (work in progress)

I am committed to protecting your privacy and being transparent about the type of personal information I hold about you.

This policy details how I collect and process information. It is important that you read and understand this policy, as well as any subsequent or additional policies that are bespoke to a particular programme or activity that I am working on, in order to understand how and why I am using your data.

This policy has been written with reference to the General Data Protection Regulation (2018).

This policy explains:

1. The nature of my work
2. Information I may hold about you
3. How I collect your data
4. How I may use your information
5. Disclosure of details to third parties
6. Security of your personal information
7. Personal data breaches
8. Data retention and your legal rights
9. Notification of changes to the privacy policy
10. Contact details for further information

1. The nature of my work

I am self-employed with a portfolio career. My work spans the following (non-exhaustive) list of activities:

• Coaching
• Mentoring
• Facilitation
• Training
• Action Learning
• Consultancy
• Programme and project management
• Voluntary work as a trustee

I work with individuals and with organisations on both a one off, short term (over a number of months) and longer-term (over a number of years) basis.

The majority of my work is within the subsidised arts and culture sector though I do, on occasion, work within and across other sectors.

I maintain membership of People Dancing and the Association for Coaching, am signed up to the update service of the Disclosure and Barring Service, have appropriate insurance and keep my practice up to date with regular training.

2. Information I may hold about you

Trust is of utmost importance in my work. I am therefore keen that you understand the personal information that I may hold about you. Personal information relates to information from which a person is identifiable. It does not include data that is depersonalised.

I will collect, store and process information about you only where I have legal basis for doing so. The information this relates to is explained as follows:

• Identity data – name, title, date of birth, gender
• Contact data – address, email address, telephone numbers, social media accounts/profiles
• Financial data – account details and payment card details
• Transaction data – details of products, services and transactions you contacted me about or purchased from me
• Marketing and communications data – information about the marketing you want to receive from me and the way in which you’d like to do so
• Usage data – how you use my website, engage with my social media, products and services
• Technical data using analytics – internet protocol (IP) address, login data, browser type/version, length of visit to pages on my website, page views, navigation paths, number of times you used my website, time zone settings and other technology on the devices you use to access my website
• Health data – next of kin and doctor details (for coaching, mentoring and action learning clients only in order to fulfil my moral obligations and duty of care)
• Sensitive data – information about criminal convictions and offences related to the Disclosure and Barring Service (when managing work with children and young people and vulnerable adults on behalf of clients. Once collected this information is immediately passed onto the client and becomes their responsibility).
• Record keeping – brief, password protected, notes recording key themes of discussions and basic actions agreed (coaching, mentoring and action learning only)
• Evaluation data – quantitative and qualitative feedback on activities, including written testimonials

In addition to the above I may collect, use and share aggregated data – statistical or demographic data which is derived from your personal information but does not reveal your identity – e.g. percentages of clients who engaged with my work in a particular way. I may also share the themes of any coaching, mentoring and action learning session with my supervisor. My work with a supervisor is covered by a confidentiality clause.

3. How I collect your data

I collect information about you in a number of different ways. This includes:

• Information you give me – when approaching me about work, when requesting or confirming my services, when registering for an event, activity or project or when signing up to my mailing list. Privacy and confidentiality will be discussed and negotiated at the outset of my work with all clients and with specific consideration given to those engaging my services for coaching, mentoring or action learning due to the nature of the data obtained and records kept
• Automated technologies or interactions – when you engage with my website or social media profiles. Here technical data may automatically be collected through cookies or other technologies. Please refer to Appendix 1 for further information about WordPress’ use of Cookies.
• Information from third parties – when analytics providers may collate information

In relation to the above, I have carefully selected the third party providers that I use to support my work and believe that they have policies for how they treat their data. These consist of the following (non exhaustive):

• WordPress (website hosting)
• Eventbrite (event registration)
• Mailchimp (email marketing)
• Google (website analytics)
• Dropbox (file storage)
• Basecamp (file storage and team communications)
• G Suite (file storage and team communications
• Slack (file storage and team communications)
• Macmail (email services)
• Yahoo (email services)
• Facebook (social media)
• Instagram (social media)
• Twitter (social media)
• Youtube (video footage)

Please review their policies if you have any concern about how they treat their data.

In addition to the above and under the Private and Electronic Communications Regulations, if you are a limited company, I may send you marketing emails without your consent. You will be able to opt out of these at any time.

4. How I may use your information

I will only use your personal information when it is lawful to do so. The lawful ground for my data collection and usage consists of:

• Legitimate business interests, as explained below:
  • To communicate with you
  • To deliver a contract for you
  • To keep records of our work together
  • To effectively administrate, monitor and secure my digital presence
  • To grow by business
• To evidence my moral and/or legal compliance and/or regulatory obligation (for some areas of my work)
• When I have your explicit consent for using your personal information in a specific situation

When communicating with you in order to promote my work I will strive to do so in ways that are respectful, relevant and time sensitive. In most cases this will be in email/digital form rather than by post.

You can opt out of postal communications by using the contact details at the end of this polity.

You can opt out of email communications by clicking the “unsubscribe” option at the bottom of every email that I send. You can opt out of other digital communications by changing your own notification settings.

5. Disclosure of details to third parties

I will never knowingly pass on your data to third company parties to use for their own gain.

However, there are circumstances when I may have to share your personal information with third parties. These consist of the following:

• Where I have chosen to work with the third party providers listed under section 3 above which provide a specific service in accordance with my instructions and with lawful respect to the privacy of your information
• Where I am seeking the professional advice of an IT support person, accountant, lawyer or insurer related to my work. Here I would ensure that they respected your personal data
• Where I have a duty to disclose your personal data to comply with any legal obligation
• Where I have a responsibility to provide funding bodies and key stakeholders with quantitative and qualitative data. This data will be anonymised unless you have given your consent for your identify to be used (e.g. for a named quote or testimonial)

6. Security of your personal information

I have put procedures in place to make sure your personal data is secure and prevent it from being accidentally lost, used, altered, disclosed or accessed without permission. This includes:

• Using password protection for information that is stored digitally
• Using anti-virus software
• Using a locked cupboard for information that is stored in hard copy format
• Ensuring any work I deliver is contracted and there are clear confidentiality clauses and data management processes
• Ensuring anyone I engage to work with me understands their responsibilities related to this policy.

7. Personal data breaches

A breach is considered any loss, alteration, unauthorised disclosure or access to personal data. I am committed to disclosing any data breach that might negatively affect you in a timely manner so that you can take appropriate action.

8. Data retention and your legal rights

The GDPR gives you the right to:

• know what data I hold about you and request access to it.
• have any data updated/corrected if it is inaccurate (I may need to see evidence to verify the accuracy of any new data)
• have any data removed entirely if you no longer consent to my use of it (though this may not always be possible if there are specific legal reasons and, if this is the case, this will be explained to you)
• object to the processing of your personal information
• request restriction to the processing of your personal information
• request to transfer of your information. We will do this in a structured community used format
• Withdraw consent
• Complain to the Information Commissioner’s Office to make a complaint (if a European citizen)
• There is no fee required for the above. However, I may charge you a reasonable fee or refuse to comply with your request if any request is unfounded, repetitive, of excessive.

In acting on any of the above I may need you to confirm your identity and ensure your right to access the data. This is a security measure to protect data.

Please use the contact details provided to make any request. I will then aim to respond within one month of receiving receipt of any request. Occasionally it may take longer it the request is complex.

9. Notification of changes to the privacy policy

This policy may change from time to time. Where I have accurate contact details I will always communicate any major change.

10. Contact details for further information

Jane Ralls (legally Keep)
Janeralls.com
janerallsdance@yahoo.co.uk

 

Appendix 1: Cookie Policy (WordPress)

What are cookies?

Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services on the website (“third party cookies”).

Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

How we use cookies

We use cookies for a number of different purposes. Some cookies are necessary for technical reasons; some enable a personalized experience for both visitors and registered users; and some allow the display of advertising from selected third party networks. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the “like” or “follow” button on a post, for example).

Many of the cookies we use are only set if you are a registered WordPress.com user (so you don’t have to log in every time, for example), while others are set whenever you visit one of our websites, irrespective of whether you have an account.

For more information on the choices you have about the cookies we use, please see the Controlling Cookies section below.

Where we place cookies

We set cookies in a number of different locations across our services. These include:

• On our websites (including automattic.com, wordpress.com, vip.wordpress.com, jetpack.com, gravatar.com, intensedebate.com, vaultpress.com, and akismet.com).
• In the administrative dashboards of our websites, such as Calypso and wp-admin.
• On sites we host for our users.
• On sites that use our plugins (e.g. Jetpack).

Types of Cookie

The table below explains the types of cookies we use on our websites and why we use them.

Category of cookies	Why we use these cookies
Strictly Necessary	These cookies are essential for websites on our services to perform their basic functions. These include those required to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” on sites that have an ecommerce functionality.
Functionality	These cookies are used to store preferences set by users such as account name, language, and location.
Security	We use these cookies to help identify and prevent potential security risks.
Analytics and Performance	Performance cookies collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use these details to improve how our websites function and to understand how users interact with them.
Advertising	These cookies are used to display relevant advertising to visitors who use our services or visit websites we host or provide, as well as to understand and report on the efficacy of ads served on our websites. They track details such as the number of unique visitors, the number of times particular ads have been displayed, and the number of clicks the ads have received. They are also used to build user profiles, including showing you ads based on products you’ve viewed or acts you have taken on our (and other) websites. These are set by Automattic and trusted third party networks, and are generally persistent in nature.
Third Party / Embedded Content	Sites hosted on WordPress.com make use of different third party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons), or embedded content from Youtube and Vimeo. As a result, cookies may be set by these third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.

User Sites

In addition to the cookies set on our own sites, we utilize cookies for our Site Stats feature. This tallies the unique numbers of visitors to a site, as well as the number from specific geographic locations. A visitor is counted when we see a user or browser for the first time in a given period.

Examples

Below are examples of the cookies set by Automattic, with explanations of their purpose. Some of these cookies are set across our whole network, whereas some are specific to individual services (e.g. WordPress.com, Longreads, etc). Please note that this is not an exhaustive list, but rather aims to be representative. Information about cookies that may be set by third parties, such as our ads partners, is below.

In addition, people and companies that use our services to publish or host their own sites may place additional cookies. We provide more information on these cookies below.

Advertising

Cookie	Purpose
ads	Tracks if a visitor has clicked an ad before.
lr_nw	Counts and tracks pageviews on Longreads.com. Used to determine whether or not to show our Membership popup message.
wordpress_eli	Reduces the display of ads for repeat visitors.

Please also see the section below on third party advertisements that you may see on our sites or sites that use our services.

Analytics and Performance

Cookie	Purpose
__pdvt	Used in log of Polldaddy survey data to aid in debugging customer problems
ab	Used for “AB testing” of new features.
nux_flow_name	Identifies which user signup flow was shown to the user.
tk_ni / tk_ai / tk_qs	Gathers information for our own, first party analytics tool about how our services are used. A collection of internal metrics for user activity, used to improve user experience.
wp-affiliate-tracker	Remembers the ID of the affiliate that referred the current user to WordPress.com
utma / utmb / utmc / utmt / utmz / ga / gat / gid	Google Analytics. Gathers information that helps us understand how visitors interact with our websites, which allow us to create a better experience for our visitors. Our users may also implement Google Analytics on their own websites.

Functionality

Cookie	Purpose
_longreads_prod_new	Authentication for Longreads.com Member accounts. Only active when logged in, on *.longreads.com domains.
akm_mobile	Stores whether a user has chosen to view the mobile version of a website.
botdlang	Used to track the language a user has selected to view popular blogs in.
landingpage_currency	Defines the currency displayed in WordPress.com landing pages.
pd_dashboard	Records last used folder in Polldaddy dashboard so it can be reopened upon user’s next visit.
PD_USER_AUTH	Login cookie used to identify Polldaddy user.
wordpress_logged_in*	Checks whether or not the current visitor is a logged in WordPress.com user.
wp-settings-{user_id}	Persists a user’s wp-admin configuration.
wp_sharing_{id}	Tracks whether or not a user has already performed an action.

Security

Cookie	Purpose
csrftoken	Python/Ajax security cookie used on accounts.longreads.com.

Strictly Necessary

Cookie	Purpose
country_code	Used in order to determine whether or not the cookie banner should be shown. Set immediately on page load and retained for 6 hours to remember the visitor’s country.
sensitive_pixel_option	Remembers the state of visitor acceptance to the cookie banner. Only set when the visitor clicks Accept.
twostep_auth	Set when the user is logged in using two factor authentication.
wordpress_test_cookie	Checks if cookies are enabled to provide appropriate user experience.

Advertisements from Third Parties Through Automattic’s Ads Program

Our mission is to democratize publishing. So that we can offer free access to create a website using WordPress.com, we show ads on some of our users’ sites. Our users may also choose to place ads on their site through our ads program. Additionally, we also show ads from our ads program on some of our own websites (e.g. longreads.com).

We operate our ads program in partnership with third party vendors. As part of the operation of our ads program, we use cookies to collect certain information. Advertising cookies enable us and our partners to serve ads and to personalize those ads based on information like visits to our sites and other sites on the Internet.

Below is a representative list of our advertising program partners, along with information on the cookies that that each partner sets. The partners we work with change from time to time, and this is not an exhaustive list. Your choices to control cookies related to our ads program are described below.

Partner	Cookie Info
Amazon	https://www.amazon.co.uk/gp/help/customer/display.html/ref=footer_iba?ie=UTF8&nodeId=201909150
AppNexus	https://www.appnexus.com/en/company/cookie-policy
BidSwitch	http://www.bidswitch.com/cookie-statement/
Criteo	https://www.criteo.com/cookie-policy/
Google (AdSense, DoubleClick Ad Exchange “AdX”)	https://policies.google.com/technologies/ads
OATH	https://policies.oath.com/us/en/oath/privacy/topics/cookies/index.html
Pubmatic	https://pubmatic.com/legal/website-cookie-policy/
Skimlinks	https://skimlinks.com/user-cookies

Visitors to Sites with Jetpack installed

Below are examples of the cookies set for visitors to sites with the Jetpack plugin installed. For more details on the cookies set for administrators, please see https://jetpack.com/support/cookies/.

Jetpack Comments

Mobile Theme

Subscriptions

EU Cookie Law Banner

Please note that this section is not intended to be exhaustive, but rather aims to be representative, and that our users may set additional cookies (such as Google Analytics), depending on the features they have chosen to enable or the plugins they have installed.

Controlling Cookies

Visitors may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior such as the length of time they are stored – either through built-in functionality or by utilizing third party plugins. If you disable cookies, please be aware that some of the features of our service may not function correctly.

To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising visit youronlinechoices.eu (EU based) or optout.aboutads.info (US based). On a mobile device, you may also be to adjust your settings to limit ad tracking.

You can opt out of Google Analytics by installing Google’s opt-out browser add-on.

Our Internal Analytics Tool

In order to better understand how our services are used, we monitor certain user activities that take place within our products, including page views and clicks on any links used when managing a site via our dashboards.

We call each one of these actions an “event.” Analytics events are attached to your WordPress.com account and are handled via a first party system that Automattic owns and maintains. In general, we record the following data for each event: IP address, WordPress.com user ID and username, WordPress.com-connected site ID (for sites not hosted on WordPress.com), user agent, referring URL, timestamp of event, browser language, and country code.

We use this information to improve our products, make our marketing to you more relevant, personalize your experience, and for the other purposes described in our Privacy Policy.

You may opt out of our analytics program through your user settings. By doing so, you won’t share information with our analytics tool about events or actions that happen after the opt-out, while logged in to your WordPress.com account. Note that opting out does not disable the functionality of the actions we track – for example, if you publish a post, we will still have record of that (don’t worry!), but for an event or action after you opt out, we will not have other data associated with that action or event in the analytics tool.

Consent for Advertising Cookies on Our Sites

You may see a “cookie banner” on our websites and dashboards. If you are visiting one of our users’ sites from the EU, then we do not set, or allow our ad partners to set, cookies that are used to show you targeted ads before you click to accept. When you consent in this manner, we and our advertising partners may set advertising cookies on the site you are visiting and on other of our websites, dashboards, and services. We’ll display the banner to you periodically, just in case you change your mind.

Consent and Choices for Advertisements on Our Users’ Sites Through Our Ads Program

You may see a “cookie banner” on our users’ websites, particularly if you are in the European Union. If so, then our ad program does not set, or allow our ad partners to set, cookies that are used to show you targeted ads before you accept. When you consent in this manner, we and our advertising partners may set third party advertising cookies on our network in order to show you personalized ads. We’ll display the banner to you periodically, just in case you change your mind.

* Please note this consent feature will start on May 22, 2018.

We set a cookie to help us understand how visitors engage with websites that participate in our ad program. Visitors may opt out of our use of this information by visiting this link (the opt-out will be processed immediately with no confirmation step). When you opt out, we replace the unique value for that cookie with an opt-out value. The opt-out works across all websites in our ads program. If you have opted out by accident, or wish to opt back in, you may do so by visiting this link. Please note that this option is browser specific, and so if you use a different device or browser or clear your cookies, then you will need to repeat the process.

Contact Us

If you have any questions about our use of cookies, you can find the most relevant contact details in our Privacy Policy.