* * * PRIVACY POLICY - Penelope Mott trading as Splendid Elk * * *

This Privacy Policy describes how and when I collect, use, and share information when you purchase an item from me, contact me, or otherwise use my services through Etsy.com or its related sites and services.

This Privacy Policy does not apply to the practices of third parties that I do not own or control, including Etsy or any third party services you access through Etsy. You can reference the Etsy Privacy Policy to learn more about its privacy practices.

1. Personal information I collect:
To fulfil your order, you must provide me with certain information (which you authorised Etsy to provide to me), such as your name, email address, postal address, payment information, and the details of the product that you’re ordering. You may also choose to provide me with additional personal information (for a custom order of personalised items, for example), if you contact me directly.

2. The Legal Base for Information Collection:
The General Data Protection Regulations (May 2018) (EU) (known as GDPR 2018 throughout the rest of this Policy) requires that I explain the legal bases I rely on to collect, use, and share your personal information. This may include a buyer’s affirmative consent to receive marketing messages, compliance with legal obligations, and a seller’s use of the personal information in their legitimate interests (improving their services, for example). Throughout this privacy policy, I will explain where and why I rely on these different legal bases

* * * WHY I NEED YOUR INFORMATION AND HOW I USE IT * * * • as needed to provide my services, such as when I use your information to fulfil your order, to settle disputes, or to provide customer support;
• when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for my mailing list;
• if necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your purchases if required by UK tax law; and
• as necessary for the purpose of my legitimate interests, if those legitimate interests are not overridden by your rights or interests, such as 1) providing and improving my services and 2) Compliance with the Etsy Seller Policy and Terms of Use.
• I use your information as necessary to comply with my obligations under the Etsy Seller Policy and Terms of Use.

3. The third parties with whom I may share personal information:
The GDPR (2018) requires that I disclose the details of any personal information I share with third parties.
Information about my customers is important to my business. I share your personal information for very limited reasons and in limited circumstances, as follows:
• Etsy. I share information with Etsy as necessary to provide you my services and comply with my obligations under both the Etsy Seller Policy and Etsy Terms of Use.
• Service providers. I engage certain trusted third parties to perform functions and provide services to my shop, such as delivery companies- for example the Royal Mail or UPS. I will share your personal information with these third parties, but only to the extent necessary to perform these services.
• Business transfers. If I sell or merge my business, I may disclose your information as part of that transaction, only to the extent permitted by law.
• Compliance with laws. I may collect, use, retain, and share your information if I have a good faith belief that it is reasonably necessary to: (a) respond to legal process or to government requests; (b) enforce my agreements, terms and policies; (c) prevent, investigate, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of my customers, or others.

4. The length of time I keep personal information:
The GDPR (2018) requires me to disclose the period of time during which I will store personal information.

* * * DATA RETENTION * * * I retain your personal information only for as long as necessary to provide you with my services and as described in my Privacy Policy. However, I may also be required to retain this information to comply with my legal and regulatory obligations, to resolve disputes, and to enforce my agreements. I generally keep your data for the following time period - 6 years as this is required of me by the UK’s Her Majesty’s Customs and Revenue Service (HMRC)

5. If transferring personal information outside of Europe, how the transfer will be handled:
GDPR (2018) requires me to disclose if I transfer personal information outside of the EU and the legal bases I rely on to do so, such as consent and contractual necessity.
The only circumstance in which I would transfer personal information out of the European Union would be for delivery purposes through trustworthy services such as the Royal Mail or UPS or similar postal services.
Any other information will only be held by Etsy itself and for that purpose you should refer to their Privacy Policy.

6. Buyers’ rights regarding my use of your personal information and my contact details:

* * * YOUR RIGHTS * * * If you reside in certain territories, including the EU, you have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. I describe these rights below:
• Access. You may have the right to access and receive a copy of the personal information I hold about you by contacting me using the contact information below.
• Change, restrict, delete. You may also have rights to change, restrict my use of, or delete your personal information. Apart from exceptional circumstances (like where I am required to store data for legal reasons) I will generally delete your personal information upon request.
• Object. You can object to (i) my processing of some of your information based on my legitimate interests and (ii) receiving marketing messages from me after providing your express consent to receive them. In such cases, I will delete your personal information unless I have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons.
• Complain. If you reside in the EU and wish to raise a concern about my use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local data protection authority.

* * * HOW TO CONTACT ME * * *
For purposes of EU data protection law, I, Penelope Mott, am the data controller of your personal information. If you have any questions or concerns, you may contact me at penny@splendidelk.co.uk

*If a customer contacts me to access, correct or delete personal information held by Etsy, I will request that the customer send a request directly to Etsy.