Privacy Policy

PRIVACY POLICY

This policy applies to all processing of personal data carried out by Sarah Cousins (dot) com and has the objective of informing the user regarding the way in which Sarah Cousins carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and regarding the rights of the user in relation to their personal data.

CONTACT

In case of having any questions about the Privacy Policy, the user can contact Sarah Cousins by email sarah@sarahcousins (dot) co (dot) uk of 71 - 75 Shelton Street, Covent Garden, London, WC2H 9JQ.

HOW PERSONAL DATA IS COLLECTED

In compliance with current regulations on the protection of personal data, especially,

• Regulation (EU) 2016/679 of the European Parliament and Council, dated April 27, 2016 on the protection of natural persons regarding the processing of personal data and the free circulation of these data (hereinafter, the “GDPR”),

This website, Sarah Cousins (dot) com, collects personal data when the user:

(i). completes the form on the “Contact” page of sarahcousins (dot) com (“Site”);

(ii). subscribes to any newsletters;

(iii). answers any polls or completes any other web form on this site;

(iv). completes a printed form;

(v). sends an email or communicates by telephone.

PERSONAL DATA COLLECTED

The following data may be collected: full name, title, position or role, name of organisation, email address, telephone number, postal address.

As a rule, when personal data is requested to use a service or access certain content, its delivery will not be mandatory, except for those cases where it is specifically indicated that it is data required for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.

The user declares and guarantees that all the data provided is true and correct and undertakes to keep them updated. The changes may be communicated to the Data Protection Delegate or to the address indicated in Section 2 hereof.

Likewise, the user acknowledges that the data required by Sarah Cousins is necessary, adequate and not excessive to carry out for the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data was not provided.

Any false or inaccurate statement which occurs as a result of the information and data given, as well as the damages that such information may cause, will be the responsibility of the user.

PURPOSE

The personal data requested from the user will be used for the following purposes:

• In the event of contracting services offered through the Site, to create and maintain the commercial relationship and to carry out the activities and provide the services of Sarah Cousins (including, without limitation, the management, administration, provision and improvement of services).

• To send newsletters, as well as commercial communications, promotions and/or advertisements of Sarah Cousins, either occasionally or periodically.

• Accordingly, the email address that the user provides when completing the form on the Site may be used to send information and updates on the request for services, as well as news about Sarah Cousins (either occasionally or periodically), updates, information on related products or services, among others. This treatment is based on our legitimate interest in promoting our products and services.

• Conduct a survey or run a contest.

• Personalise the user's experience, increasing our ability to respond to their needs.

• Improve the Site and the service offer of Sarah Cousins, based on the legitimate interest of Sarah Cousins in constantly improving its products and services.

• Process transactions and comply with the legal obligations to which Sarah Cousins is subject, such as tax obligations. The data subject to treatment will not be used for purposes other than or incompatible with those mentioned above and that motivated its collection. Notwithstanding the foregoing, it is stated that the recorded data may be used, in addition to the purposes for which it was expressly collected, for the purpose of carrying out statistics, managing incidents or conducting market studies. However, in the event that personal data is processed for a purpose other than that initially specified when collecting said data, a compatibility analysis will be carried out by Sarah Cousins in accordance with applicable regulations. The processing will only be authorised if the original purpose is compatible with the new purpose or allowed in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or legal justification for the processing of their data. We remind the user that they can oppose the sending of commercial communications (unsubscribe) and stop receiving emails from Sarah Cousins, reliably notifying Sarah Cousins, which will proceed to interrupt in the shortest possible time after receiving such communication. For this purpose, please send an email to the address indicated in Section 2, or reply "unsubscribe" to an email from Sarah Cousins.

HOW YOUR INFORMATION IS USED

We will use the information that we collect about you for the following purposes:

• Administration info

• Customer care

• Contractual delivery of services

If we want to use your information for any other purpose, we will ask for your consent and will use your information only upon receiving your consent and then, only for the purpose(s) for which consent was granted, unless we are required to do otherwise by law.

We will retain your personal information for 60 months after your account has remained idle, or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy.

CONSENT

By providing personal data to Sarah Cousins, the user declares to accept their data being processed fully and unreservedly by Sarah Cousins. The user hereby grants his free, express and informed consent for Sarah Cousins to use the data collected for the purposes indicated in Section 5 hereof, as well as its incorporation into a Sarah Cousins database.

Sarah Cousins carries out the processing of the user's data legitimised in: (i) the contracting of Sarah Cousins services by the user, in accordance with the terms and conditions that are made available to the user at the end of completing the request form for services (prior to a possible hiring) and that the user (after reading it) and if they agree, can accept by checking the box that has been included for this purpose; and (ii) the free, informed and unequivocal consent of the user, made after reviewing this privacy policy where Sarah Cousins informs the treatment that it will carry out with your data and if you agree, by checking the box that has been included for this purpose in the service request form. The processing of data that is not covered by any of the legal bases indicated above, will be carried out if Sarah Cousins considers it necessary to protect a legitimate interest and only if they do not contravene the fundamental rights and freedoms of the user.

EXPIRATION

Your data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes detailed in Section 5 above. In particular, personal data will be kept as long as the business relationship is in force (and to the extent that the user has not previously requested its deletion) and during the period during which obligations, indemnities and/or responsibilities may arise under the business relationship or for the services provided.

Sarah Cousins informs that essential information will be retained to identify the origin of the data stored for the duration of the client's relationship with Sarah Cousins and/or revocation of consent by the user in accordance with the information in Section 5 of this Privacy Policy and / or the time required by applicable law.

CONFIDENTIALITY AND THIRD PARTIES

Sarah Cousins will keep the personal data collected private and confidential and will not use data for purposes other than those established in Section 5 hereof. Sarah Cousins requires the signing of confidentiality agreements and personal data processing by its employees and third parties that provide services that access the content of the databases (or include such obligations within the service agreements that it signs with such providers as indicated in the next paragraph).

The personal data of the user collected by Sarah Cousins will not be transferred, sold, exchanged, transmitted and/or communicated to any third party outside of Sarah Cousins' business without the consent of the user, except legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers which allow Sarah Cousins to keep the Site operational, comply with the purposes established in Section 5 hereof and/or provide services to the user, who have assumed the obligation to maintain the confidentiality of the data provided and commit to compliance with the applicable regulations on the protection of personal data, at the time of hiring. The contracts with the service providers stipulate the objective, scope, content, duration, nature and purpose of the data processing, the type of personal data, the categories of data owners and the obligations and responsibilities of Sarah Cousins and of the contracted third parties.

In particular: Sarah Cousins may share the personal information provided with controlling companies, affiliates, subsidiaries, related companies and/or intermediaries related to Sarah Cousins. Sarah Cousins may share certain personal information provided by the user internally within the business, with certain departments, such as administration, marketing, or IT.

- SOCIAL NETWORKS

Sarah Cousins also uses social networks, such as Facebook, Instagram, Twitter and LinkedIn and has integrated functions of these networks into some services. The user may only use these social networks to the extent that they are registered in them and have accessed the corresponding social network with their own details. These social networks have their own privacy policies and their own terms and conditions, over which Sarah Cousins has no interference or control.

Finally, the user must know that Sarah Cousins may (and that Sarah Cousins reserves the right to) disclose their information in the following cases: (i) if required by a judicial or administrative authority; (ii) if necessary in order to exercise your rights under the Terms and Conditions of Sarah Cousins and under this Privacy Policy; (iii) if necessary to comply with the law; (iv) if said data could be useful for the protection of the rights of third parties; (v) when it is useful for the protection of the rights, property or security of Sarah Cousins, its controllers, subsidiaries, affiliates, directors, managers, employees, users or the general public; and (vi) when there are well-founded reasons related to public security, national defense, or public health.

SECURITY

Sarah Cousins declares their intention to adopt the technical and organisational measures necessary to guarantee the security, integrity, and confidentiality of the data in accordance with the provisions of the GDPR in order to avoid its adulteration, loss, consultation or unauthorised processing.

Sarah Cousins does not guarantee absolute privacy in the use of the Site since the possibility that unauthorised third parties may have knowledge of it should not be ruled out. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are adopted, it is possible to suffer manipulation, destruction and / or loss of information. In the event that a security incident is detected and that it implies a significant risk for the owner of the data, such event will be communicated without delay to the competent control authority, together with the corrective and palliative measures implemented and / or to be implemented.

Sarah Cousins is not responsible for the loss or deletion of data by users. Likewise, Sarah Cousins does not accept any responsibility for possible damages caused by computer viruses.

Finally, the user must also take measures to protect their information. Sarah Cousins insists that you take every precaution to protect your personal information while on the Internet. At least, you are advised to change your password periodically, using a combination of letters and numbers, and make sure you are using a secure browser.

YOUR RIGHTS

You may at any time exercise the rights of access, rectification, cancellation, opposition, limitation of processing, portability, confidentiality and deletion regarding your own personal data, in accordance with the provisions of articles 15 and following of the GDPR, as appropriate.

The exercise of these rights can be carried out by identifying yourself through an email addressed to sarah@sarahcousins (dot) co (dot) uk, or by any of the methods provided for in the applicable regulations referenced above. Sarah Cousins may request the necessary data to validate the identification of the owner of the data.

The deletion of some data will not proceed when it could cause damage to the legitimate rights or interests of third parties, or when there is a legal obligation to keep the data.

TRAINING

Any staff whose functions are related to the processing of personal data are trained in order to guarantee better protection of personal data and the rights of its holders.

LINKS TO THIRD PARTIES

This Site may contain links to third party sites, with or without advertising content, whose privacy policies are foreign to Sarah Cousins. The linked sites are not related to Sarah Cousins and, their existence in no way presupposes that there is any kind of suggestion, invitation, or recommendation for the visit of the destination places or any kind of link or association between Sarah Cousins and such sites. Sarah Cousins is not responsible or liable for the content, use and activities of these linked websites, or for damages, whether current or eventual, material or moral, direct or indirect, suffered by users and derived from the information contained in such sites or of the relationship that users may establish with third parties whose services have been published on the Site. Notwithstanding the foregoing, any comment on these linked websites will be useful to Sarah Cousins in order to improve services and/or ensure the integrity of the Site. Sarah Cousins undertakes to do everything possible to prevent the existence on its Site of links to sites with illegal content.

COOKIES

When the user enters the Site, Sarah Cousins may store some information on their computer in the form of a "cookie" or similar file. The Site uses cookies to (i) track advertising, (ii) collect data about Site traffic, and (iii) improve the user experience when using the Site.

The user should know that to navigate the Site, it is not necessary for the user to allow the installation of cookies sent by the Site. This may only be required in relation to certain services. The user can erase cookies from the hard drive of his/her computer, prevent access to his/her computer either through his/her browser or by choosing the corresponding option when asked about the possibility of using cookies for these purposes and in compliance with the Cookies Policy of Sarah Cousins.

Cookies are information files that a website or the provider of certain services of the site transfers to the hard drive of the user's computer through the browser program. Cookies by themselves cannot personally identify the user (although they can contain the user's IP address) but they allow them to recognise the user's browser and capture and store certain data (user's operating system, domain name of the website from which the Site was linked, among others). Sarah Cousins reserves the right to contract the services of third parties to analyse and understand the users of the Site, who may not use the information collected for purposes other than to improve Sarah Cousins services.

APPROVAL

The use of the Site by the user implies the knowledge and full approval of the Privacy Policy of Sarah Cousins and the Terms and Conditions of Sarah Cousins (dot) com, if any. Likewise, the user accepts the Privacy Policy of Sarah Cousins (dot) com and the Terms and Conditions of Sarah Cousins (dot) com by completing the request for services.

MODIFICATIONS

This is the current version of the Sarah Cousins Privacy Policy, updated on June 28, 2023.

Sarah Cousins may at any time and without prior notice, modify this Privacy Policy. Such modifications will be operative from their publication on the Site or when they are notified to users by any means, whichever occurs first. The user must keep informed about the terms included here by reviewing periodically.