Privacy Policy

Privacy – March 2018
Website privacy notice

1. INTRODUCTION
This privacy notice provides you with details of how I collect and process your personal
data through your use of my websites www.depressionbustingcourses.com and
www.demischneider.com including any information you may provide through my site when
you sign up for a free gift, or purchase a product or service, or book a free consultation.
By providing us with your data, you warrant to us that you are over 18 years of age.
Demi Schneider is the data controller and I am responsible for your personal data.
My full details are: Demi Schneider
Postal address: Beech House, Beech Close, Willand, EX15 2SD
Email address: demischneider@me.com

If you are not happy with any aspect of how I collect and use your data, you have the right
to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority
for data protection issues (www.ico.org.uk). I should be grateful if you would contact me
first if you do have a complaint so that I can try to resolve it for you.
It is very important that the information I hold about you is accurate and up to date. Please
let me know if at any time your personal information changes by emailing me at
demischneider.com

2. THE DATA I COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not
include anonymised data.
I may process certain types of personal data about you as follows:
Identity Data may include your first name, last name, marital status, title, date of birth and
gender.
Contact Data may include your address, email address and telephone numbers.
Transaction Data may include details about payments between us and other details of
purchases made by you.
Usage Data may include information about how you use my website, products and
services.
Marketing and Communications Data may include your preferences in receiving
marketing communications from me.
I may also process Aggregated Data from your personal data but this data does not reveal
your identity and as such in itself is not personal data. An example of this is where we
review your Usage Data to work out the percentage of website users using a specific

feature of our site. If we link the Aggregated Data with your personal data so that you can
be identified from it, then it is treated as personal data.
Sensitive Data: I need to collect the following sensitive data about you in order to be able
to help you in my programmes and courses:
Information about your health
Information about personal issues and your desired outcomes
Information about addictions, convictions, past treatments, private struggles, relationships,
or anything else relating to the help you are wanting from me.

3. HOW I COLLECT YOUR PERSONAL DATA
I collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on my site (or otherwise) or by
communicating with me by post, phone, email or otherwise, including when you:
order my products or services;
subscribe to a service or publication;
request resources or marketing be sent to you;
give me feedback/testimonial

4. HOW I USE YOUR PERSONAL DATA
I will only use your personal data when legally permitted. The most common uses of your
personal data are:
Where I need to perform the contract between us.
Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, I do not rely on consent as a legal ground for processing your personal data,
other than in relation to sending communications to you via email or text message. You
have the right to withdraw consent to this at any time by unsubscribing at the bottom of an
email or emailing me at demischneider.com
Purposes for processing your personal data
Set out below is a description of the ways I intend to use your personal data and the legal
grounds on which I will process such data. I have also explained what my legitimate
interests are where relevant.
Lawful basis for processing
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your programme including:

(a) Manage payments, fees and charges
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
To manage my relationship with you which will include:
(a) Notifying you about changes to my terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for my legitimate interests to keep my records updated and to study how
customers use my products/services
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for my legitimate interests to study how customers use my products/
services, to develop them and grow my business

To administer and protect my business and my site (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for my legitimate interests for running my business, provision of
administration and IT services, network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the
effectiveness of my advertising
(a) Identity
(b) Contact
(c) Profile

(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests to study how customers use our products/services,
to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve my website, products/services, marketing, customer
relationships and experiences
(a) Technical
(b) Usage
Necessary for my legitimate interests to define types of customers for my products and
services, to keep my site updated and relevant, to develop my business and to inform my
marketing strategy

To make suggestions and recommendations to you about goods or services that may be of
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests to develop our products/services and grow our
business

Marketing communications
You will receive marketing communications from me if you have:
(i) requested information from me or purchased goods or services from me; or
(ii) if you provided me with your details when you entered a competition or registered for a
promotion or free resource; and
(iii) in each case, you have not opted out of receiving that marketing.
You can ask me to stop sending you marketing messages at any time by emailing me
at demischneider@me.com
Where you opt out of receiving my marketing communications, this will not apply to
personal data provided to me as a result of a product/service purchase, warranty
registration, product/service experience or other transactions.
Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I
reasonably consider that I need to use it for another reason and that reason is compatible
with the original purpose.

If I need to use your personal data for a purpose unrelated to the purpose for which I
collected the data, I will notify you and I will explain the legal ground of processing.
I may process your personal data without your knowledge or consent where this is
required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA
I may have to share your personal data with the parties set out below for the purpose of
running my business:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide
consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom
and other relevant jurisdictions who require reporting of processing activities in certain
circumstances.

6. DATA SECURITY
I have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In
addition, I limit access to your personal data to those employees, agents, contractors and
other third parties who have a business need to know such data. They will only process
your personal data on my instructions and they are subject to a duty of confidentiality.

7. DATA RETENTION
I will only retain your personal data for as long as necessary to fulfil the purposes I
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.
To determine the appropriate retention period for personal data, I consider the amount,
nature, and sensitivity of the personal data, the potential risk of harm from unauthorised
use or disclosure of your personal data, the purposes for which I process your personal
data and whether I can achieve those purposes through other means, and the applicable
legal requirements.
By law I have to keep basic information about my customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being customers for tax
purposes.
In some circumstances you can ask me to delete your data: see below for further
information.
In some circumstances I may anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case I may use this
information indefinitely without further notice to you.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your
personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/
individual-rights/
If you wish to exercise any of the rights set out above, please email me at
demischneider@me.com

You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, I may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, I may refuse to comply with your request in these
circumstances.

I may need to request specific information from you to help me confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights).
This is a security measure to ensure that personal data is not disclosed to any person who
has no right to receive it. I may also contact you to ask you for further information in
relation to your request to speed up my response.
I will try to respond to all legitimate requests within one month. Occasionally it may take
me longer than a month if your request is particularly complex or you have made a number
of requests. In this case, I will notify you and keep you updated.

9. THIRD-PARTY LINKS
My website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data
about you. I do not control these third-party websites and am not responsible for their
privacy statements. When you leave my website, I encourage you to read the privacy
notice of every website you visit.