Graham Shapiro Design Ltd (“we”, “us”, “GSD®”) are committed to protecting and respecting your privacy. This policy (together with our terms of website use) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
As the Data Controller, Graham Shapiro Design Ltd Ltd has implemented numerous technical and organisational measures to ensure the most comprehensive protection of personal data processed through this website. However, whilst we take every reasonable step (for example by using an encrypted connection between your website browser and our website), Internet-based data transmissions may in principle have security gaps outside of our control, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable and other provisions related to data protection is:
Graham Shapiro Design Ltd, Tudor House, 73 Welsh Row, Nantwich, Cheshire CW55EW
01270 625130 / firstname.lastname@example.org
Personal data – means any information relating to an identified or identifiable natural
person (“data subject”). An identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an identification number,
location data, an online identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person.
Processing – is any operation or set of operations which is performed on personal data or on sets of
personal data, whether or not by automated means, such as collection, recording, organisation,
adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction.
Restriction of processing – is the marking of stored personal data with the aim of limiting their
processing in the future.
Profiling – means any form of automated processing of personal data consisting of the use of personal
data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict
aspects concerning that natural person’s performance at work, economic situation, health, personal
preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation – is the processing of personal data in such a manner that the personal data can no
longer be attributed to a specific data subject without the use of additional information, provided that
such additional information is kept separately and is subject to technical and organisational measures to
ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller or controller responsible for the processing – is the natural or legal person, public
authority, agency or another body which, alone or jointly with others, determines the purposes and means
of the processing of personal data; where the purposes and means of such processing are determined by Union
or Member State law, the controller or the specific criteria for its nomination may be provided for by
Union or Member State law.
Processor – is a natural or legal person, public authority, agency or another body which processes personal
data on behalf of the controller.
Recipient – is a natural or legal person, public authority, agency or another body, to which the personal data
are disclosed, whether a third party or not. However, public authorities which may receive personal data
in the framework of a particular inquiry in accordance with Union or Member State
law shall not be regarded as recipients; the processing of those data by those public authorities shall be
in compliance with the applicable data protection rules according to the purposes
of the processing.
Third party – is a natural or legal person, public authority, agency or body other than the data subject,
controller, processor and persons who, under the direct authority of the controller or processor, are
authorised to process personal data.
Consent – of the data subject is any freely given, specific, informed and unambiguous indication of
the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies
agreement to the processing of personal data relating to him or her.
stored in a computer system via an Internet browser.
unique identifier of the cookie. It consists of a character string through which Internet pages and servers
can be assigned to the specific Internet browser in which the cookie was stored. This allows visited
Internet sites and servers to differentiate the individual browser of the data subject from other Internet
browsers that contain other cookies. A specific Internet browser can be recognized and identified
using the unique cookie ID.
By use of a cookie, the information and offers on our website can be optimized with the user in mind.
Cookies allow us, as previously mentioned, to recognise our website users. The purpose of this recognition
to enter access data each time the website is accessed, because this is taken over by the website, and
the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping
cart in an online shop. The online store remembers the articles that a customer has placed in the
virtual shopping cart via a cookie – without which the user would need to add things to their basket again
on each unique visit.
The data subject may, at any time, prevent the setting of cookies through our website by means of a
corresponding setting of the Internet browser used, and may thus permanently deny the setting of
cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other
software programs. This is possible in all popular Internet browsers. If the data subject deactivates
the setting of cookies in the Internet browser used, not all functions of our website may be
2. COLLECTION OF GENERAL DATA & INFORMATION
The Graham Shapiro Design Ltd website collects a series of general data and information when a data
subject or automated system calls up the website. This general data and information are stored in
the server log files. Collected data may be (1) the browser types and versions used, (2) the operating
system used by the accessing system, (3) the website from which an accessing system reaches our
website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site,
(6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system,
and (8) any other similar data and information that may be used in the event of attacks on
our information technology systems.
When using these general data and information, Graham Shapiro Design Ltd does not draw any
conclusions about the data subject. Rather, this information is needed to (1) deliver the content
of our website correctly, (2) optimise the content of our website as well as its advertisement, (3)
ensure the long-term viability of our information technology systems and website technology, and (4)
provide law enforcement authorities with the information necessary for criminal prosecution in case
of a cyber-attack. Therefore, Graham Shapiro Design Ltd analyses anonymously collected data and
information statistically, with the aim of increasing the data protection and data security of our organisation,
and to ensure an optimal level of protection for the personal data we process. The anonymous data
of the server log files are stored separately from all personal data provided by a data subject.
3. WEBSITE CONTACT FORM
The Graham Shapiro Design Ltd website contains information that enables electronic contact with
our organisation, as well as direct communication with us, which also includes an email address.
If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted
by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a
data subject to the data controller are stored for the purpose of processing or contacting the data
subject. There is no transfer of this personal data to third parties.
4. ERASURE AND BLOCKING OF PERSONAL DATA
The data controller shall process and store the personal data of the data subject only for the period
necessary to achieve the purpose of storage, or as far as this is granted by legislators in laws or
regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the legislator or another
competent legislator expires, the personal data is routinely blocked or erased in accordance with
5. YOUR RIGHTS
a) Right of confirmation
Each data subject shall have the right granted by the legislator to obtain from the controller the
confirmation as to whether or not personal data concerning him or her are being processed. If a data
subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any
employee of the controller.
b) Right of access
Each data subject shall have the right granted by the legislator to obtain from the controller free
information about his or her personal data stored at any time and a copy of this information.
Furthermore, the directives and regulations grant the data subject access to the following information; the
purposes of the processing and/or, the categories of personal data concerned etc. If a data subject
wishes to avail himself of this right of access, he or she may, at any time, contact any
employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the legislator to obtain from the controller without
undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the
purposes of the processing, the data subject shall have the right to have incomplete
personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time,
contact any employee of the controller.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the legislator to obtain from the controller the
erasure of personal data concerning him or her without undue delay, and the controller shall have the
obligation to erase personal data without undue delay where one of the following grounds applies,
as long as the processing is not necessary by law:
The personal data are no longer necessary in relation to the purposes for which they were collected or
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1)
of the GDPR, or point (a) of Article 9(2)
of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are
no overriding legitimate grounds for the processing or the data subject objects to the processing
|pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State
law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred
to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of
personal data stored by Graham Shapiro Design Ltd, he or she may, at any time, contact any
employee of the controller. An employee of Graham Shapiro Design Ltd Ltd shall promptly
ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to
erase the personal data, the controller, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to inform other controllers
processing the personal data that the data subject has requested erasure by such controllers of any
links to, or copy or replication of, those personal data, as far as processing is not required.
An employee of Graham Shapiro Design Ltd will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the legislator to obtain from the controller
restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the
controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data
and requests instead the restriction of their use.
The controller no longer needs the personal data for the purposes of the processing, but they
are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending
the verification whether the legitimate grounds of the controller override
those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the
restriction of the processing of personal data stored by Graham Shapiro Design Ltd, he or she
may at any time contact any employee of the controller. The employee of Graham Shapiro Design
Ltd will arrange the restriction of the processing.
f) Right to data portability / Subject Access Requests
Each data subject shall have the right granted by the legislator, to receive
the personal data concerning him or her, which was provided to a controller, in a structured,
commonly used and machine-readable format. He or she shall have the right to transmit
those data to anothercontroller without hindrance from the controller to which the personal data
have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1)
of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b)
of Article 6(1)of the GDPR, and the processing is carried out by automated means, as long as the
processing is not necessary for the performance of a task carried out in the public interest or in the
exercise of official authority vested in the controller. Furthermore, in exercising his or her right to data
portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have
personal data transmitted directly from one controller to another, where technically feasible and when
doing so does not adversely affect the rights and freedoms of others.In order to assert the right to
data portability, the data subject may at any time issue a subject access request, in writing
to Graham Shapiro Design Ltd.
g) Right to object
Each data subject shall have the right granted by the legislator to object, on grounds relating to his
or her particular situation, at any time, to processing of personal data concerning
him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR.
This also applies to profiling based on these provisions. Graham Shapiro Design
Ltd shall no longer process the personal data in the event of the objection unless
we can demonstrate compelling legitimate grounds for the processing which override
the interests, rights and freedoms of the data subject, or for the establishment,
exercise or defence of legal claims.
If Graham Shapiro Design Ltd processes personal data for direct marketing
purposes, the data subject shall have the right to object at any time to
processing of personal data concerning him or her for such marketing. This applies to profiling
to the extent that it is related to such direct marketing.
If the data subject objects to Graham Shapiro Design Ltd to the processing for direct
|marketing purposes, Graham Shapiro Design Ltd will no longer process the personal
data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation,
to object to processing of personal data concerning him or her by Graham Shapiro Design
Ltd for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1)
of the GDPR, unless the processing is necessary for the performance of a task carried out
for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of
Graham Shapiro Design Ltd. In addition, the data subject is free in the context of the use
of information society services, and notwithstanding Directive 2002/58/EC, to use his or
her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the legislator not to be subject to a
decision based solely on automated processing, including profiling, which produces legal effects
concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is
necessary for entering into, or the performance of, a contract between the data subject and a
data controller, or (2) is not authorised by law to which the controller is subject and which also
lays down suitable measures to safeguard the data subject’s rights and freedoms and
legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between
the data subject and a data controller, or (2) it is based on the data subject’s explicit consent,
Graham Shapiro Design Ltd shall implement suitable measures to safeguard the data subject’s rights
and freedoms and legitimate interests, at least the right to obtain human intervention on the part of
the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual
decision-making, he or she may, at any time, contact any employee of
Graham Shapiro Design Ltd.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the legislator to withdraw his or her
consent to processing of his or her personal data at any time. If the data subject wishes
to exercise the right to withdraw the consent, he or she may, at any time, contact any
employee of Graham Shapiro Design Ltd.
6. LEGAL BASIS
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations
for which we obtain consent for a specific processing purpose. If the processing of personal
data is necessary for the performance of a contract to which the data subject is party, as is the case,
for example, when processing operations are necessary for the supply of goods or
to provide any other service, the processing is based on Article 6(1) lit. b GDPR.
The same applies to such processing operations which are necessary for carrying out
pre-contractual measures, for example in the case of inquiries
concerning our products or services.
Is our company subject to a legal obligation by which processing of personal data is
required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1)
lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the
vital interests of the data subject or of another natural person. This would be the case,
for example, if a visitor were injured in our company and his name, age, health insurance
data or other vital information would have to be passed on to a doctor, hospital or other third party.
Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations
could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which
are not covered by any of the above mentioned legal grounds, if processing is necessary for the
purposes of the legitimate interests pursued by our company or by a third party, except where
such interests are overridden by the interests or fundamental rights and freedoms of the data
subject which require protection of personal data. Such processing operations are
particularly permissible because they have been specifically mentioned by the legislator.
He considered that a legitimate interest could be assumed if the data subject is a client of
the controller (Recital 47 Sentence 2 GDPR).
7. LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY
Where the processing of personal data is based on Article 6(1)
lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all
our employees and the shareholders.
8. PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
The criteria used to determine the period of storage of personal data is the respective
statutory retention period. After expiration of that period, the corresponding data is routinely
deleted, as long as it is no longer necessary for the fulfilment of the contract or the
initiation of a contract.
9. PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT;
REQUIREMENT NECESSARY TO ENTER INTO
A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE
PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE
We clarify that the provision of personal data is partly required by law (e.g. tax regulations)
or can also result from contractual provisions (e.g. information on the contractual partner).
Sometimes it may be necessary to conclude a contract that the data subject provides us
with personal data, which must subsequently be processed by us. The data subject is,
for example, obliged to provide us with personal data when our company
signs a contract with him or her.
The non-provision of the personal data would have the consequence that the contract with the
data subject could not be concluded. Before personal data is provided by the data subject,
the data subject must contact any employee. The employee clarifies to the data subject
whether the provision of the personal data is required by law or contract or is necessary
for the conclusion of the contract, whether there is an obligation to provide the
personal data and the consequences of non-provision of the personal data.
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