Your privacy is protected at all times in accordance with the terms set out below.

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1. Introduction

1.1    Cecilia Place (“CP”) is committed to safeguarding the privacy of its website visitors and service users.

1.2    This policy applies where CP is acting as a data controller with respect to the personal data of its website visitors and service users; in other words, where CP determines the purposes and means of the processing of that personal data.

1.3    CP uses cookies on its website. To the extent those cookies are not strictly necessary for the provision of CP’s website and services, CP will ask you to consent to our use of cookies when you first visit our website.

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2. How CP uses your personal data

2.1    This section 2 sets out:

(a)    the general categories of personal data that CP may process;

(b)    the purposes for which CP may process personal data; and

(c)    the legal bases of the processing.

2.2    CP may process data about your use of our website and services (“usage data“). 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. The source of the usage data is Google Analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interest in monitoring and improving our website experience and services.

2.3    CP may process your account data (“account data“). The account data may include your name and email address. The source of the account data is provided by you. The account data may be processed for the purposes of operating CP’s website, providing CP’s services, ensuring the security of CP’s website and services, maintaining back-ups of CP’s databases and communicating with you. The legal basis for this processing is CP’s legitimate interests, namely the proper administration of its website and business, or the performance of a contract between you and CP and/or taking steps, at your request, to enter into such a contract.

2.4    CP may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender and date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of CP’s website and services. The legal basis for this processing is CP’s legitimate interests, namely the proper administration of CP’s website and business, or the performance of a contract between you and CP and/or taking steps, at you request, to enter into such a contract.

2.5    CP may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name, address, telephone number, email address, profile pictures, gender and date of birth. The source of the service data is you. The service data may be processed for the purposes of operating CP’s website, providing CP’s services, ensuring the security of CP’s website and services, maintaining back-ups of CP’s databases and communicating with you. The legal basis for this processing is CP’s legitimate interests, namely the proper administration of CP’s website and business, or the performance of a contract between you and CP and/or taking steps, at your request, to enter into such a contract.

2.6    CP may process information that you post for publication on CP’s website or through CP’s services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering CP’s website and services. The legal basis for this processing is consent or CP’s legitimate interests, namely the proper administration of CP’s website and business, or the performance of a contract between you and CP and/or taking steps, at your request, to enter into such a contract.

2.7    CP may process information contained in any enquiry you submit to CP regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.8    CP may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between CP and you. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing CP’s relationships with customers, communicating with customers, keeping records of those communications and promoting CP’s products and services to customers. The legal basis for this processing is consent to CP’s legitimate interests, namely the proper management of CP’s customer relationships.

2.9    CP may process information relating to transactions, including purchases of goods and services, that you enter into with CP and/or through CP’s website (“transaction data“). The transaction data may include your contact details, your card 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 CP and/or taking steps, at your request, to enter into such a contract and CP’s legitimate interests, namely the proper administration of CP’s website and business.

2.10  CP may process information that you provide to CP for the purpose of subscribing to CP’s email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, or the performance of a contract between you and CP and/or taking steps, at your request, to enter into such a contract.

2.11  CP may process information contained in or relating to any communication that you send to CP (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. CP’s 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 CP’s legitimate interests, namely the proper administration of CP’s website and business and communications with users.

2.12  CP may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is CP’s legitimate interests, namely the protection and assertion of CP’s legal rights, your legal rights and the legal rights of others.

2.13  CP 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 CP’s legitimate interests, namely the proper protection of CP’s business against risks.

2.14  In addition to the specific purposes for which CP may process your personal data set out in this Section 2, CP may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which CP is subject, or in order to protect your vital interests or the vital interests of another natural person.

2.15  Please do not supply any other person’s personal data to CP, unless CP prompts you to do so.

2.16   Our database is only accessible by those authorised with special access rights to CP’s server, and are required to keep the information confidential. In the case of a personal data breach (in the event of a cyber attack, for example), CP shall notify you via email no later than 72 hours of becoming aware of the breach.

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3. Providing your personal data to others

3.1     CP may disclose your personal data to CP’s 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, whether in court proceedings or in an administrative or out-of-court procedure.

3.2     In addition to the specific disclosures of personal data set out in this Section 3, CP may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which CP is subject, or in order to protect your vital interests or the vital interests of another natural person. CP may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

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4. International transfers of your personal data

4.1    In this Section 4, CP provides information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2    CP has offices and facilities in Australia. The European Commission has made an “adequacy decision” with respect to the data protection laws of certain countries. Transfers to certain countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, or Australia’s Privacy Act, a copy which can be found at https://www.legislation.gov.au/Details/C2014C00076.

4.3    The hosting facilities for CP’s website are situated in Australia. The European Commission has made an “adequacy decision” with respect to the data protection laws of countries outside the European Economic Area. Transfers to Australia will be protected by appropriate safeguards, namely Australia’s Privacy Act, a copy which can be obtained from https://www.legislation.gov.au/Details/C2014C00076

4.4    You acknowledge that personal data that you submit for publication through CP’s website or services may be available, via the internet, around the world. CP cannot prevent the use (or misuse) of such personal data by others.

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5. Retaining and deleting personal data

5.1    This Section 5 sets out CP’s data retention policies and procedure, which are designed to help ensure that CP complies with its legal obligations in relation to the retention and deletion of personal data.

5.2    Personal data that CP processes for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3    CP will retain your personal data as follows:

(a)    Your name and email address will be retained for a minimum period of 6 months following 25.05.18, and for a maximum period of 5 years following 25.05.18.

5.4    In some cases it is not possible for CP to specify in advance the periods for which your personal data will be retained. In such cases, the period of retention of your name and email address will be determined based on your engagement with our website, content and services.

5.5    Notwithstanding the other provisions of this Section 5, CP may retain your personal data where such retention is necessary for compliance with a legal obligation to which CP is subject, or in order to protect your vital interests or the vital interests of another natural person.

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6. Amendments

6.1    CP may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

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7. Your rights

7.1    This section 7 summarises the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2    Your principal rights under data protection law 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 CP processes your personal data and, where CP 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, CP 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 access your personal data when logged into CP’s website, or by email at info@cecilia.place if you need assistance.

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; CP no longer needs the personal data for the purposes of 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, CP may continue to store your personal data. However, CP 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 CP’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 us; or the purposes of the legitimate interests pursued by CP or by a third party. If you make such an objection, CP will cease to process the personal information unless CP 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 CP’s processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, CP will cease to process your personal data for this purpose.

7.9    You have the right to object to CP’s 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 our 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 CP 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 our 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 CP’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 CP in addition to the other methods specified in this Section 7.

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8. About cookies

8.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

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9. Cookies that we use

9.1  CP uses cookies for the following purposes:

(a)    authentication – to identify you when you visit CP’s website and as you navigate our website.

(b)    status – to help CP determine if you are logged into CP’s website.

(c)    personalisation – to store information about your preferences and to personalise the website for you.

(d)    security – an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect CP’s website and services generally.

(e)    advertising – to help CP to display advertisements that will be relevant to you (cookies used for this purpose are: Facebook pixels).

(f)    analysis – to help CP to analyse the use and performance of CP’s website and services (cookies used for this purpose are: Google Analytics).

(g)    cookie consent – to store your preferences in relation to the use of cookies more generally.

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10. Cookies used by our service providers

10.1  CP’s service providers use cookies and those cookies may be stored on your computer when you visit CP’s website.

10.2  CP uses Google Analytics to analyse the use of CP’s website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to CP’s website is used to create reports about the use of CP’s website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

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11. Managing cookies

11.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/welcome/mac (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2  Blocking all cookies will have a negative impact upon the usability of many websites.

11.3  If you block cookies, you will not be able to use all the features on CP’s website.

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12. CP’s contact details

12.1  This website is owned and operated by Cecilia Place.

12.2  CP is registered in Australia under ABN number XXXXXXXXXXX.

12.3 CP’s registered office is at 6 Moorakyne Avenue, Malvern, VIC 3144.

12.4  CP’s principal place of business is at 6 Moorakyne Avenue, MALVERN VIC 3144.

12.5  You can contact CP:

(a)    by post, at the postal address given above; or

(b)   by email, at info@cecilia.place.