Introduction and scope
I Can Compose Ltd is committed to protecting the privacy and personal data of all those whose data we are handling and to working within the guidelines set out by data protection law. This privacy information notice aims to provide you with information about how and why we are, plan or may be using information about you. It also explains how you can exercise the rights you have set out in the law and how you can contact us if you have any concerns or questions about data protection.
I Can Compose will comply with the requirements of data protection legislation, including the UK General Data Protection Regulation and the Data Protection Act 2018.
This policy relates to personal data collected and processed relating to our customers and suppliers, prospective customers and former customers and suppliers.
Data Controller
The legal data controller is Rachel Shapey, I Can Compose, 6 Mount St, Harrogate, North Yorkshire HG2 8DQ. We have appointed a Privacy Officer to oversee our processing of personal information whose contact details are provided below (privacy@icancompose.com).
Information we may be holding about you
We collect, create and otherwise obtain and process the following types of personal data:
- Personal identifiers – name, address and email address which you provide to us through our enquiry or contact forms and which we use a) to fulfil the request you make (e.g. purchasing a product, subscribing to the newsletter etc.) and b) to create a database of people who have expressed interest in our companies or products and services, to provide services you request, fulfilling requests for information etc. We may also use this information to validate your identity via Facebook authentication services if you sign up to our services via social media.
- Your feedback and opinions which you provide to us through our enquiry or contact forms which we use allow us to answer queries and complaints you may have and to help us evaluate the quality and consistency of our services.
- Details of your visits to our website including your IP address, pages visited, dwell time, and page referred from which we collect from your browser to enable us to monitor the performance and relevance of our website.
- If you join our communications program we collect information about each email we have sent to you and your interaction with them including the number of times opened, deliverability, which sections you clicked on etc. which we use to measure the effectiveness of our email campaigns, to plan marketing campaigns and to segment our database.
We may also undertake additional data processing activities but will ensure they are compatible with the purposes above. If we choose to process your personal data for any incompatible purpose we will provide you with appropriate privacy information at the point where you come across those additional purposes.
The legal basis for processing is in pursuant of our legitimate interests as a commercial business seeking to promote, develop and grow our business through the sale of products and services and to provide excellent customer services. If you buy any products or services from our website the legal basis for processing personal data about you in those circumstances is the fulfilment of our contract
with you brought about by the transaction.
Disclosing, sharing and transferring your personal data We will disclose information about you with some of our suppliers who process data on our behalf to help us to provide services to you. We undertake this data sharing on the basis of our legitimate interests to procure high quality, cost effective services. The table below provides you with information about the categories of organisation we may share information with:
| Categories of Organisation | Purpose | Location |
| Marketing agencies, database hosting companies, data cleansing companies, mailing housing, and email broadcasters.(Mailchimp) | To provide marketing services and fulfil our email program. | United States |
| Social Media which may include but not be limited to: Facebook, Twitter, Linked In, Instagram, YouTube. | To verify your identify when you register on our website | United States |
| Online payment processing platform (Stripe) | Processing electronic payments on the website. | United States/Ireland |
| Google Analytics (Google Analytics with anonymized IP; Google Analytics Advertising Reporting Features; Google Analytics Demographics and Interests reports) | To provide data and insights into how customers use the website. | United States |
| Website hosting & maintenance (Nettl of Stockport) | To maintain the website | UK |
We may also share information about you with other companies within our group (see About Us) where we think you may have an interest in their products and services. We undertake this on the basis of their legitimate interests in promoting their products and services and undertaking direct marketing.
We may also disclose your personal information to third parties from time to time:
a) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation;
b) to fulfil any order that you place with us (e.g. we would share data with our retail partner, mailing houses, credit card companies and banks etc.);
c) to enforce or apply our terms of use and other agreements;
d) to protect the rights, property, or safety of our business, our customers, or others including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
International Transfer of Personal Data
If you chose to sign-up via Social Media when you register on our Site we may access your personal data in your Facebook account depending on your Facebook settings and we may post information you submit on our Site to Facebook who will store such information in the United States of America. The UK has not endorsed the privacy laws of the United States but has approved a framework for the transfer of personal data called standard contractual clauses which we have entered into with Facebook enabling us to lawfully transfer your personal data to Facebook in the US. A copy of the safeguards we have in place is available by contacting our Privacy Officer.
Data retention:
We will hold information about you in our data systems only for as long as we need to hold it which is generally as follows:
- As long as you continue to use our services and log into our website we will retain and process information about you. User accounts are automatically suspended when they have been inactive (i.e. users have not logged in and/or have not opened our emails) for a period
of five years. Inactive accounts are still maintained on our data systems. - We will hold information about how you interact with our electronic communications for a period not exceeding 2 years from the campaign start date after which we will anonymise it to enable us to continue to analyse the performance of our campaigns but without being
able to attribute any specific information to you. - Any personal data linked to insurance claims is retained indefinitely.
We reserve the right to review our retention policy and to shorten our retention periods if we feel this is appropriate. We will not lengthen our retention periods without letting you know.
Your Rights
The GDPR grants you certain rights (‘information rights’) which we summarise below:
| Right of access and of data portability. | You have the right of access to information we hold about or concerning you and/or to have it transferred to another data controller in some circumstances. If you would like to exercise this right you should contact our Privacy Officer. |
| Right of rectification or erasure. | If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will/shall take all reasonable steps to inform those with whom we have shared your data about your request for erasure. |
| Right to restriction of processing. | You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don’t need to hold your data anymore but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data. |
| Right to object. | You have a right to object to our processing of your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling. |
| Right to Withdraw Consent. | You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent. To withdraw consent please select the unsubscribe option in the most recent electronic marketing communication you have received or alternatively you can write to us info@icancompose.com. |
| Right of Complaint. | You also have a right to lodge a complaint about any aspect of how we are handling your data with the UK’s Information Commissioner’s Office who can be contacted at www.ico.org.uk. |
If you would like to find out more about your rights please contact our Privacy Officer.
Information Governance and our Privacy Officer
We have appointed a Privacy Officer who is responsible for helping us to comply with our legal obligations set out in the UK GDPR. The privacy officer monitors our data protection compliance and provides advice and guidance as to how we can improve our data handling practices. The contact details
of our Privacy Officer are available on our website and may change from time to time. At the time of writing our Privacy Officer is:
Rachel Shapey
I Can Compose
We reserve the right to change our privacy officer without informing you directly and will publish our privacy officer contact details on our website.
29 November 2021
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