1. Introduction
This privacy policy is about how CATHERINECARRINGTON.COM collects, processes, stores and shares client’s data.
This Privacy Policy only relates to personal data collected by the CATHERINECARRINGTON.COM via the CATHERINECARRINGTON.COM website, application forms, emails and telephone calls. Any personal data collected by the CATHERINECARRINGTON.COM is used in accordance with UK data protection legislation.
Users should be aware that if they access other websites, using the links provided, these are outside our control. If they provide personal data to other companies, the privacy policies of those companies determine the uses to which that information is put and the CATHERINECARRINGTON.COM Privacy Policy will no longer apply.

2. The Data Protection Bill 2017
CATHERINECARRINGTON.COM complies with the principles of the Data Protection Bill 2017 in accordance with General Data Protection Regulations (GDPR).

3. Purpose of data  
The data we collect from clients is the data required to provide professional services to clients, communicate with clients and validate and verify the legitimacy of clients.  The data held by CATHERINECARRINGTON.COM is collected at the time of application by clients and includes name, surname, home address, email, phone number(s).

4. Disclosures - Sharing of data
We may disclose your personal information (including to trusted third parties) for the purposes for which is primarily held or for a related secondary purpose and in some cases we may disclose information without your consent. Your personal and sensitive information may be disclosed to CATHERINECARRINGTON.COM employees, CATHERINECARRINGTON.COM representatives, service providers we use to deliver aspects of our service such as database or email software facilities.
Data is shared via client numbers with insurance providers for the purposes of verifying the legitimacy of insurance applicants.
Data is shared internally with administrators for the purpose of verifying payments.

5. Legacy data
Clients to CATHERINECARRINGTON.COM accepted or otherwise are kept on record for up to 3 years. 

6. Device specific data
The following information may be collected through your device and browser:
·        Your devices IP address (collected and stored in an anonymized format)
·        Your email address including first name and surname
·        Device screen size
·        Device type (unique identifiers) and browser information
·        Geographic location (country only)
·        Preferred language used to display the webpage

7. Digital Log data
Our servers automatically record information which is created using our software. Data includes:
·        Referring domain
·        Pages visited
·        Geographic location (country only)
·        Preferred language used to display information
·        Date and time when pages were accessed or created 

8. Consent
Clients of CATHERINECARRINGTON.COM consent via their application to receive information relating to the activities of CATHERINECARRINGTON.COM in the form of newsletters, regulatory updates, webinars, events, special offers and information relevant to the profession.

9. Opting out
Opt out mechanisms are in place on all CATHERINECARRINGTON.COM mailings and communications. Users can choose to opt out at any time by clicking the opt-out button at the bottom of mailings or emailing CATHERINECARRINGTON.COM directly with a request to opt out.

10. Use Made of Personal Information
Personal information provided to CATHERINECARRINGTON.COM will be used for the purposes of providing services to clients.  Any personal information that is collected by CATHERINECARRINGTON.COM will be used by CATHERINECARRINGTON.COM only in accordance with current data protection legislation.
In addition, personal information may be used for statistical analysis.
Processing personal data for the above purposes may entail sharing the information with employees, contractors, agents and professional advisors and regulators of CATHERINECARRINGTON.COM.
Written agreements exist between CATHERINECARRINGTON.COM and such parties that there must be no further disclosure of such personal data.

11. Consent
By providing personal data to CATHERINECARRINGTON.COM users consent to the processing of such data by CATHERINECARRINGTON.COM as described in this Privacy Policy. 

12. Verifying, updating and amending your personal information
If, at any time, a client wants to verify, update or amend their personal data they may email to:
catherine@CATHERINECARRINGTON.COM
Verification, updating or amendment of personal data takes place within 10 working days 

13. Storage of personal data
Data is stored in a secured, encrypted, cloud based database. Payments are processed according to the requirements of 12.9 PCI DSS v3.2 in accordance with PCI security standards.

14. Processing of data
Personal and financial data is processed and handled via Stripe.
All personal data is fully backed up and stored in highly secure AWS data centres with 24/7 infrastructure monitoring, with immediate notification and recovery in place in the event of a data breach.

15. Cookies
A “cookie” is a small text file that is placed on a user’s computer hard drive by a website. There are several types of cookie and the most common are often referred to as ‘session’ cookies. These are used to keep track of information needed by a user as they travel from page to page within a website. These cookies have a short lifetime and expire within a few minutes of the user leaving the site.
Other types of cookies can be used to track internet activity after the user has left a website. These are usually sponsored by organisations external to the website being visited and are generally known as ‘third party’ cookies. These usually have a long lifetime with several months being quite common. They are ‘harvested’ and ‘refreshed’ whenever the user visits a page where the same or a similar cookie is being used.
CATHERINECARRINGTON.COM uses benign, short lived ‘session’ cookies to tell whether a website user has logged in, where to find details that can be used to pre-fill parts of on-line forms and to personalise the user’s visit to the website.
CATHERINECARRINGTON.COM cookies do not analyse visits to other websites or any searches undertaken whilst on the CATHERINECARRINGTON.COM website.
Internet browsers normally accept cookies by default; however, it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful session cookies. Choose an option that rejects all third party and long lived cookies.
CATHERINECARRINGTON.COM uses cookie free technology that uses Internet Protocol (IP) information exchanged during the course of normal web activity combined with data enhancement technology to get detailed analytics information.
 
16. Links to Third Party Websites
This Privacy Policy applies solely to the personal data collected by the CATHERINECARRINGTON.COM and does not apply to third party websites.
CATHERINECARRINGTON.COM is not responsible for the privacy policies of third party websites. CATHERINECARRINGTON.COM advises users to read the privacy policies of other websites before registering any personal data.

17. Security
CATHERINECARRINGTON.COM holds your personal data in accordance with the security provisions of the UK data protection legislation.
If you have any questions about security please contact the CATHERINECARRINGTON.COM.

18. Notification of Changes
CATHERINECARRINGTON.COM will notify all users of any changes it makes to its Privacy Policy. If CATHERINECARRINGTON.COM decides to change its Privacy Policy, it will post such changes on this page so that you are always aware of how CATHERINECARRINGTON.COM uses your personal data.
Users have the right to ask CATHERINECARRINGTON.COM in writing, for a copy of all the personal data held about them upon payment of a fee (“subject access request”) and to request that CATHERINECARRINGTON.COM correct any inaccuracies in that information.

19. Your rights over your data
You have the right to rectify, amend, correct or erase your data except where there is a legal basis for refusal.