We take safeguarding online privacy seriously. Please read the whole of this statement carefully as it sets out what information we may collect from you, how we may use it, and your rights as a data subject in respect of our use and the key details of our Privacy Policy.

Our Privacy Statement governs any kind of processing where we are acting as a data controller or co- controller (including collection, use, transfer, storage and deletion) of personally identifiable information (any information that may be used to identify a physical person, and any other information associated therewith) about natural persons. This statement applies to our processing of data collected through any means, actively as well as passively, from persons located anywhere in the world.

From time to time, we may need to change our Privacy Policy because of changes in our organisation, legislation, or in our attempts to serve your needs better. We will use reasonable efforts to publish any changes to our Privacy Statement.

Brunton GmbH is responsible for collecting, processing, storing, and safe-keeping personal and other information as part of providing a service and carrying out our regular business activities. We manage personal information in accordance with the Data Protection Act and any other applicable data protection legislation.

Any questions regarding our processing of personal data should be directed to us via email to: hello@sanderlingcreative.com.

SCOPE

Our Privacy Statement governs any kind of processing where we are acting as a Data Controller or co- controller (including collection, use, transfer, storage, and deletion) of personally identifiable information (any information that may be used to identify a physical person, and any other information associated therewith) about natural persons. This Privacy Statement applies to our processing of data collected through any means, actively as well as passively, from persons located anywhere in the world.

We are guided by the following principles when processing data:

• We will only collect data for specific and specified purposes; we will make it clear at the point when we request your information, what we are collecting it for and how we are going to use it; We will not collect data beyond what is necessary to accomplish those purposes; we will minimise the amount of information we collect from you to what we need to deliver the services required; We will collect and use your personal information only if we have sensible business reasons for doing so, such as contacting you with a weekly newsletter or to provide you with an update in respect to our programmes and services;

• We will not use your data for purposes other than those for which it was collected, accepted as stated within our Privacy Policy, or without your prior consent;

• We will seek to verify and/or update your data periodically and we will accept requests from you for amendment of the data held;

• We will apply high technical standards to make our processing of data secure;

• Except otherwise stated, we will not store data in identifiable form longer than is necessary to accomplish its purpose or as required by law.

INFORMATION COLLECTED

The information we may collect about you could include, but is not limited to:

• Personal details

• Lifestyle and social circumstances

• Financial and business details

If we obtain special category data from you we will always get your consent first. We will make it clear at the point when we request your information, what we are collecting special category data for and how we are going to use it.

We will collect information from you when:

• You sign up to our newsletter or mailing list

• You download an opt-in

• You join one of our courses

• You contact us for information via our website or social media channels or by email 

• You post or comment on our social media channels, website, or blog

• You work with us in a commercial capacity 

We may use the information collected to:

• Allow you to purchase one of our courses and / or services

• Send you our newsletters or provide you with information, products, or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes

• Ensure that content from our site is presented to you in the most effective manner for you and your computer

• Allow you to participate in the service you have chosen to do so

• Notify you about changes to our service.

INFORMATION COLLECTION AND STORAGE

If you provide us with your email address it will be stored, along with your first name via our email marketing software, We currently use Kit (ConvertKit) who has their own data protection policy. Find it at https://kit.com/privacy

We will never sell or share your personal information with third parties.

LEGAL BASIS FOR PROCESSING YOUR DATA

The General Data Protection Regulation (GDPR) dictates that at least one of the following applies:

• You have consented

• For the performance of a contract

• For compliance with a legal obligation which we must perform 

• To protect vital interests of yours or another person

• It is in the public interest

• It is in the legitimate interests pursued by us or a third party

We collect data for the purposes set out above. Data is managed to ensure that it is either erased from our system when it is no longer required for the purpose for which it was collected, retained for legal reasons, or minimised and retained.

DATA RETENTION

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. This is for purchase and transaction records, including your name, email address, and purchase history.

Email subscriber data, including your name and email address, is retained for as long as you remain subscribed to our mailing list or have an active relationship with us. If you unsubscribe, your data will be suppressed from future communications but may be retained in our records to honour your opt-out preference and to maintain accurate purchase and interaction history.

Where you request deletion of your data and there is no legal obligation requiring us to retain it, we will action your request within 30 days.

LINKS FROM OUR WEBSITE

Our site may contain links to and from other websites, and these are operated by individuals and companies over which we have no direct control. If you follow a link to any of these websites, please note that these websites have their own privacy and terms of use policies. We do not accept any responsibility or liability for these policies. We advise you to check the policies for third party sites before you submit any personal data to the website.

SHARING OF DATA WITH AFFILIATES

We work with trusted affiliates and in doing so it may be necessary to provide third party affiliates with information so that they can deliver services to you as part of your purchase.

We also affiliate for other trusted businesses and their products and services when we believe they are of service to our audience, and in these cases it may also be necessary to provide them with information (name and email) to verify the leads and sales we have directed to them.

If an affiliate is connected to a purchase you make, then they may receive a copy of your name and your email address, they may also be aware of the purchase price of any transaction made through our site. We do not store card or payment information and so would never transfer such information. Please contact us before making a purchase if you do not wish for your information to be shared with an affiliate. Please be aware that you may not be able to receive affiliate bonuses if your contact information is not provided to the third party affiliate who will be fulfilling such a bonus.

MARKETING EMAILS AND NEWSLETTERS

We will make it as easy as we can for you to opt out of unwanted processing, providing it does not restrict our ability to provide you with the primary service you have requested.

Please note if you wish to unsubscribe from any marketing emails and / or newsletters that you have signed up for, you can do so by clicking onto the unsubscribe link on the marketing email and / or newsletter that was sent to you. It may take 48 hours for this to become effective.

We use Google Analytics to analyse website traffic. This involves an international transfer of data to Google's servers. Google Analytics collects anonymised data about how visitors interact with our website. You can opt out of Google Analytics tracking by using the Google Analytics Opt-out Browser Add-on available at tools.google.com/dlpage/gaoptout.

For the most part, the capture of any data will be anonymous. At all times when you are using our site you should have the ability to select marketing preferences and opt in or out of your data being captured as to your preference.