Privacy Policy

1. What is Personal Data

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Personal data means any information relating to an identified or identifiable natural person. 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.  

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2. General Principles for Personal Data Processing by Annette Cherubin

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I adhere to the following principles when processing your personal data, in line with the UK GDPR:

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• Lawfulness, Fairness, and Transparency: Personal data will be processed lawfully, fairly, and in a transparent manner in relation to you. This policy aims to provide that transparency.  

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• Purpose Limitation: Personal data will be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.  

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• Data Minimisation: Personal data collected will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.  

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• Accuracy: Personal data will be accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate are erased or rectified without delay.  

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• Storage Limitation: Personal data will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.  

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• Integrity and Confidentiality: Personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.  

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• Accountability: As the data controller, I am responsible for and able to demonstrate compliance with these principles.  

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3. Personal Data We Collect and Process

 

I may collect and process the following data about you:

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• Data You Give Us When Placing an Order: This includes information you provide when placing a commission for a pet painting, such as your name, email address, phone number, delivery address, and billing address. This is necessary for the performance of our contract.

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• Information About Your Commission: This includes the name of your pet, the canvas size you select, and any specific instructions or preferences you provide for the painting. This is necessary for the performance of our contract.

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• Image Data of Your Pet: You will upload photographs of your pet for the purpose of the commission. This is necessary for the performance of our contract.

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• Payment Information: When you make a payment through our website, the transaction is processed by Wix Payments, which facilitates various payment methods including credit/debit cards, Apple Pay, and potentially other options. I do not directly collect or store your sensitive payment card details. Wix Payments will collect and process your payment information in accordance with their own privacy policy and security practices. The final payment for the commission is then completed via a direct bank transfer from you to my (Annette Cherubin's) bank account, details of which will be provided separately. Processing via Wix Payments is necessary for the initial payment stage, and bank transfer details are processed based on contractual necessity.

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• Communication Data: If you contact me via email, contact forms, or phone, I will collect and process the information you provide in these communications. This is based on my legitimate interest in managing customer inquiries and providing support.

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• Data We Collect Automatically Via Our Website: With regard to each of your visits to our site, I may automatically collect technical data, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information, and browsing patterns (e.g., pages visited, time spent on pages, links clicked). This processing is based on my legitimate interest in ensuring the security and functionality of my website and understanding user behavior to improve it. I may also collect behaviour information via the use of cookies and similar technologies, based on your consent where required (as detailed in Section 10).

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• I may also collect behaviour information via the use of cookies and similar technologies, including tracking pixels from advertising platforms like Meta (Facebook) and Google Ads. These technologies help us understand your interactions with our website and deliver relevant advertisements to you.

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4. Legal Bases for Processing Your Personal Data

 

I will only process your personal data when I have a lawful basis for doing so under the UK GDPR. These bases include:

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• Contract: Processing your order details, image of your pet, and delivery information is necessary to fulfill your commission and deliver the painting. Processing payment information via Wix Payments and your bank details is necessary to receive payment for the services.

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• Legitimate Interests: To analyse website usage to improve our website and services, for ensuring website security, and for managing customer inquiries and support, provided that these interests do not override your rights and freedoms.

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• Consent: For marketing communications (if you implement them) and for certain non-essential cookies. You have the right to withdraw consent at any time.

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• Legal Obligation: If required by law.

 

5. How I Use Your Personal Data

 

I use data held about you in the following ways:

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• To send you marketing communications if you have provided your explicit consent to do so, and to personalize your experience and deliver targeted advertising through platforms like Meta (Facebook) and Google Ads, and to measure the effectiveness of our marketing campaigns using tracking pixels and Google Tag Manager.

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• To process and fulfill your commission for a pet painting, including creating the artwork and arranging delivery.

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• To communicate with you regarding your commission, including updates, questions, and delivery information.

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• To process the initial payment for your orders via Wix Payments.

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• To provide you with my bank details to complete the final payment via direct bank transfer.

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• To provide customer support and respond to your inquiries.

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• To improve our website and services based on usage data and user feedback.

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• To ensure the security and functionality of our website.

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• To send you marketing communications if you have provided your explicit consent to do so.

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• To comply with my legal and regulatory obligations.

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• To personalise your experience and deliver targeted advertising through platforms like Meta (Facebook) and Google Ads, and to measure the effectiveness of our marketing campaigns using tracking pixels and Google Tag Manager.

 

6. Our Disclosure of Your Personal Data to Third Parties

 

I do not sell your personal data. I may disclose personal information about you to third parties where reasonably necessary for the various purposes set out above:

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• To Wix Payments for the purpose of processing the initial stages of your payment through their platform, which may involve various payment methods you choose (e.g., credit/debit card, Apple Pay). Please refer to the Wix.com Privacy Policy and their Wix Payments Terms of Service for details on how they handle your payment information.

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• To shipping providers (e.g., Royal Mail, couriers) to deliver your artwork.

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• To service providers who host our website and information technology systems or otherwise process your information on my behalf, under strict conditions of confidentiality and security (Data Processing Agreements will be in place).

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• To analytics and tag management providers (e.g., Google Tag Manager) who assist us in implementing and managing tracking technologies on our website.

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• To relevant authorities if required by law.

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• To our marketing service providers, who assist us with marketing activities, subject to appropriate data processing agreements.

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• To social media platforms like Meta (Facebook) for the purpose of delivering targeted advertising and measuring the effectiveness of our campaigns. Please refer to Meta's privacy policy for details on how they handle your data.

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• To advertising platforms like Google Ads for the purpose of delivering targeted advertising and measuring the effectiveness of our campaigns. Please refer to Google's privacy policy for details on how they handle your data.

 

7. International Transfer of Your Information

 

The information that I collect from you may be transferred to, and stored at, a destination outside of the United Kingdom. This includes service providers and third-party platforms I use, such as website hosting providers and analytics services, which may have servers located globally. Where I transfer your personal data outside of the UK, I will ensure that appropriate safeguards are in place to protect your personal data in accordance with the UK GDPR. This may include transferring to countries deemed to provide an adequate level of data protection under UK law or implementing Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO) with the recipient. I will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this privacy policy.  

 

8. Retention of Your Information

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I will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying:

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1 any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, 2 I consider the volume, 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 3 I process your personal data, and whether I can achieve those purposes through other 4 means, as well as the applicable legal, regulatory, tax, accounting, or other obligations.

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• Customer Order Data (including contact details, address, commission details, payment records): I will typically retain this data for a maximum of 7 years from the end of the relevant tax year. This extended period accounts for potential audits, legal claims, and comprehensive business record-keeping.

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• Image Data of Pets: Images provided for commissions will be retained for a maximum of 2 years after the commission is completed. This allows for potential re-orders, portfolio reference, and showcasing my artistic style. However, you have the right to request deletion of your pet's image at any time, and I will comply with such requests unless there is a compelling legitimate reason or legal obligation to retain it.

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• Marketing Data (email addresses for newsletter subscriptions): I will retain your email address for marketing purposes for as long as you remain subscribed to our mailing list. If you unsubscribe, your email address will be removed from our active marketing lists promptly. For record-keeping purposes to ensure your opt-out is respected, a minimal record of your unsubscription may be retained indefinitely in an anonymised format.

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• Communication Data (emails, contact form submissions): I will typically retain general inquiries and related communications for a period of 2 years from the date of the communication to ensure I can address any follow-up questions or issues effectively and maintain a record of our correspondence.

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• Website Analytics Data: Website usage data collected via analytics cookies will be retained in accordance with the policies of Google Analytics and my own configuration settings, typically for a period of up to 2 years to allow for comprehensive analysis of website trends and user behavior over time.

 

Please note that these retention periods may be extended if required to comply with legal or regulatory obligations, to resolve disputes, or to enforce our agreements. In such cases, I will ensure that the data is processed only for those specific purposes and for the duration required by the applicable obligation or necessity.

 

Once the retention period for a specific type of personal data expires, it will be securely deleted or anonymised in accordance with my data destruction policies.

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9. Your Rights Under the UK General Data Protection Regulation (GDPR)

 

Under the UK GDPR, you have the following rights regarding your personal data:

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• The right to be informed: You have the right to be informed about the collection and use of your personal data. This privacy policy aims to fulfill this right.  

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• The right of access: You have the right to request a copy of the personal data I hold about you.

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• The right to rectification: You have the right to ask me to correct any inaccurate or incomplete personal data I hold about you.  

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• The right to erasure ('the right to be forgotten'): You have the right to ask me to delete your personal data under certain circumstances.

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• The right to restriction of processing: You have the right to ask me to restrict the processing of your personal data under certain circumstances.  

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• The right to object to processing: You have the right to object to the processing of your personal data for direct marketing purposes and, in certain situations, to processing based on legitimate interests.  

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• The right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller, where technically feasible and the processing is based on consent or contract.  

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• The right to withdraw consent: If I am processing your personal data based on your consent, you have the right to withdraw that consent at any time.

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• Rights in relation to automated decision making and profiling: [State if you engage in this; if not, state that you do not].

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• The right to lodge a complaint: You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you believe that I have not complied with data protection laws.

 

To exercise any of these rights, please contact me using the details provided below. I may require you to verify your identity before responding to your request. I will respond to your request without undue delay and within one month of receipt of your request.

 

10. Cookies and Similar Technologies

 

Our website, pet-paintings.com, uses cookies and similar technologies such as pixels and tags to enhance your browsing experience, understand how our site is used, personalise content (such as showing you relevant examples of pet portraits), and for marketing purposes. This section provides detailed information about the types of cookies we use, their purposes, and how you can manage your preferences.

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What are Cookies?

 

Cookies are small text files that are placed on your computer or mobile device when you visit a website. They allow the website to remember your actions and preferences over a period of time.

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Types of Cookies We Use:

 

We use the following categories of cookies on our website:

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• Essential Cookies: These cookies are necessary for the basic functionality of our website, such as enabling you to browse the site, use the shopping cart (if implemented in the future), and ensuring the website operates as expected. These cookies cannot be disabled. The legal basis for these cookies is typically our legitimate interest in providing a functional website.

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• Marketing Cookies: These cookies are used to track advertising effectiveness and deliver more relevant ads to you based on your interests in pet paintings. They may also be used to limit the number of times you see an advertisement and help measure the effectiveness of our advertising campaigns. We use platforms such as Google Ads and Meta Pixel for these purposes. These cookies are only placed with your explicit consent.

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• Functional Cookies: These cookies may be used to remember choices you make (such as language preferences or display settings) to improve your experience on our website. These cookies are only placed with your explicit consent.

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• Analytics Cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. This data allows us to analyse website traffic, identify popular pages (like specific portrait styles), and improve the overall performance and usability of our site. We use tools such as Google Analytics for this purpose. These cookies are only placed with your explicit consent.

 

Third-Party Cookies:

 

Please note that third-party services we use, such as Wix (our website platform), payment processors (Wix Payments), and advertising platforms (Google Ads, Meta Pixel), may also place cookies on your browser. The use of these cookies is governed by the respective third parties' privacy and cookie policies, which we encourage you to review. We also use Google Tag Manager to manage these third-party tracking codes on our website.

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Managing Your Cookie Preferences:

 

When you first visit our website, you will be presented with a cookie consent banner that allows you to manage your preferences for non-essential cookies. You can:

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• Accept All Cookies: Consent to the use of all categories of cookies.

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• Settings: Customise your preferences by enabling or disabling Marketing, Functional, and Analytics cookies. Essential cookies cannot be disabled as they are necessary for the website to function.

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• Decline Non-Essential Cookies: Refuse the use of Marketing, Functional, and Analytics cookies.

 

You can also review and manage your cookie preferences at any time by clicking the "Cookie Preferences" link in the footer of our website. Clicking this link will bring you back to this "Managing Your Cookie Preferences" section of our Privacy Policy, where you can find information on how to control cookies through your browser settings.

 

While our website platform currently does not offer a direct link to re-open the cookie consent banner after it has been dismissed, you can manage your cookie settings directly through your web browser. Instructions on how to do this for common browsers are provided in the "Browser Controls" section below.

 

We also have our cookie consent banner set to reappear periodically for returning visitors, allowing you another opportunity to review and update your preferences.

 

Browser Controls:

 

In addition to the initial consent banner and the information provided in this section, you can manage all cookies, including those already set, through the settings of your web browser. Most browsers allow you to block or delete cookies, or to be notified before a cookie is stored. Please refer to your browser's help documentation for instructions on how to manage your cookie preferences (e.g., search for "manage cookies [your browser name]").

 

Wix Payments Cookies:

 

If you make payments through our website using Wix Payments, Wix may also set cookies to enable secure payment processing and fraud prevention. Information about how Wix handles your data, including in relation to payments, can be found in the Wix.com Privacy Policy and their Wix Payments Terms of Service. We encourage you to review these policies for more details.

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Updates to this Cookie Policy:

 

We may update this Cookie Policy from time to time to reflect changes in our use of cookies or legal requirements. The date of the latest update will be indicated at the beginning of our overall Privacy Policy.

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11. Responsible for Processing

 

Annette Cherubin is the data controller and is responsible for the processing of your personal data.

 

12. Contact Me

 

I welcome questions, comments, and requests regarding this privacy policy and my processing of personal information. Please contact me by email at: annettecherubin@gmail.com