This website is the property of Calm Babies and, we are committed to protecting and respecting your privacy always.
This Policy aims to give you information about when and why we gather personal data from people who visit our website, or who get in touch with us for any reason, including by phone or email. It also explains how we use your personal data, the conditions under which we may disclose it to others, how we keep your data secure, and it sets out your privacy rights.
We may change this policy from time to time by updating this page. Additional information may be provided on particular pages of this website, for example, on any specific pages where we collect personal data and you should also refer to those. We also operate cookies on our website and information about that is also provided separately in our Cookies Policy.
How to Contact
For any questions about this Policy, or to exercise any of your legal rights, please contact our designated Data Protection Officer, Catherine Timson, via our contact form.
Who Are We?
We are Calm Babies. For the purposes of this website, the information collected through it and information collected through our contract, Calm Babies is a data controller and is responsible for your personal data. We gather and process your personal data in accordance with this Policy, and in compliance with the General Data Protection Regulation (“GDPR”) and other relevant data protection laws and regulations.
What Type of Information Do We Collect?
Personal data means any information about an individual from which that person can be identified. It does not include any data which has been anonymised such that a person’s identity is removed. We collect, use, store and transfer different kinds of personal data.
The categories of personal data that we collect from you may include:
Identity and Contact Data such as name, title, home address, and personal phone numbers and email addresses.
Technical Data including internet protocol (IP) address, access times, browser type, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This may also include information about how you use our website and our services. This is done through Google Analytics, and it is in place to improve our website and thus the user experience.
Marketing and Communications Data includes preferences in receiving marketing from us, and your communication preferences.
Financial Data including information you may need to provide us with to make a payment. This may include credit/debit card information, and your bank account details.
“Special Categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information with your explicit consent, such as photographs, or if you tell us about a disability that affects your or your child’s learning. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or your child’s interests) and you are not capable of giving your consent, or where you have already made the information public.
How Do We Collect Your Data?
This data is collected in several ways. Often it is collected using the forms when you enrol, as well as via email and/or phone communication. We may collect the data directly from you also.
How Do We Use Your Data?
We are committed to respecting the personal data you supply us with and we will only use your personal data where the law allows us to. The following information explains the purposes for which we use different categories of personal data and the legal basis or bases which we believe applies to those uses.
Administering Our Website
We may process your identity and contact data, profile data and technical data for the purposes of administering and operating this website. This may include troubleshooting, data analysis, testing, system maintenance and support. This helps us to continually improve this website and the services we can offer. We process your data in this way on the basis that this is necessary for our legitimate interests in managing, administering and improving this website and our services.
Managing Our Relationship with You
We may process your identity and contact data for the purposes of managing our relationship with you and communicating with you in relation to our services. We may also process your financial data to issue you with our invoices and to administer payments. We process your data in this way on the basis that it is necessary to do so for the performance of the relevant contract that you have entered with us.
If you contact us with a comment, enquiry (for example via one of our online forms) or if you want to speak to us, we use your identity and contact data to respond to you. Processing your data in this way is necessary for our legitimate interests in the operation of our business, to provide our customer service to you.
Similarly, if you contact us in response to a job vacancy we advertise on our website, or any recruitment portal or if you send us information to apply for a role with us on a speculative basis, we will process your career data to assess your suitability for employment with us, and to contact you. We process your personal data in this way on the basis that this is necessary in our legitimate interests in fulfilling our staffing requirements.
We may from time to time contact you with marketing communications such as to tell you about other services we offer which we think may interest you, or to seek your views and feedback on the services we provide. To do this we will use your identity and contact data, and may also use your technical, profile and marketing and communications data. We process your data in this way as it is necessary for our legitimate interests to develop, market and promote our services. We provide further information about this when you agree to receive our promotional offers and marketing communication.
You are free to withdraw this consent at any time. You can opt-out from our marketing communications by contacting Calm Babies via the contact form.
We only retain your personal data for as long as it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Unless otherwise stated in our Data Retention Policy, to determine the appropriate retention period for personal data, we 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For more information on this please refer to our Data Retention Policy (to be uploaded shortly) which lists how long we hold your personal information for.
Who Has Access to Your Information?
Calm Babies does not and will not share or disclose your personal information with unconnected third-parties without your consent, unless it is for purposes specified in this Policy or if there is a legal requirement.
We also limit access to your personal data to those employees, group companies, agents, contractors and other third parties who have a business need to know it. We will only disclose the data the relevant party needs to perform their function, they will only process your personal data on our instructions and they are also subject to a duty of confidentiality.
If you provide personal data to us, we take reasonable technical and organisational steps to keep it secure and to prevent it from being accidentally lost, used or accessed in an unauthorised way. We will notify you and any applicable regulator of a breach where we are legally required to do so.
Transferring Your Information Outside of the European Union (EU)
Your personal data is often stored outside of the EU, and as part of our marketing activities we accept personal data from a range of marketing channels such as Mailchimp. For example, information such as your name and email address is electronically transferred and stored on a Mailchimp database and stored on their database in a country outside of the EU. Whenever we transfer your personal data outside of the EU, we take all steps necessary to ensure it remains protected under frameworks and agreements in destination countries that are compliant with EU data regulations. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.
Consequences of Not Providing Your Data
Calm Babies will never make you provide us with your personal data, nor are you obligated to do so. Where we need to collect personal data by law, under the terms of a contract we have with you or for another lawful reason and you fail to provide that data, it may restrict us from offering some or all of our services. It may also prevent us from fully performing our obligations in accordance with our contract, or otherwise properly dealing with a request or enquiry you have made.
Updating Your Personal Data
Links to Other Websites
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights are listed below. Please contact us if you would like to exercise any of them. You have the right to:
Request access to your personal data (a “data subject access request”). This means you can receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. You can ask us to remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing, where we may have processed your data unlawfully or where we are required to erase your personal data to comply with law. We may not always be able to comply with your request where there are particular legal reasons.
Object to processing of your personal data where we rely on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You can also object to direct marketing. In some cases, we may demonstrate that we have grounds to process your data which override your rights and freedoms.
Request restriction of processing. You can ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our data use is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer need it, to establish, exercise or defend legal claims; or you have objected to use of data but we need to verify whether we have overriding legitimate grounds to use it.
Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information which you provided consent for us to use or necessary to perform a contract with you.
Withdraw consent at any time where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw your consent.
Exercising Your Rights
You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us 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 personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests in which case we will keep you updated.
Lodging A Complaint
We will only process your personal data in compliance with this Policy and all relevant laws and regulations. If you have cause for concern or are unhappy in any way, you may lodge a complaint with us using the contact details set out above.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, like the opportunity to assist you with any concerns before you approach the ICO.