Legal Notices

Privacy policy

1. Introduction

1.1 I am committed to safeguarding the privacy of our website visitors

1.2 This policy applies where I am acting as a data controller with respect to the personal data of such persons; in other words, where I determine the purposes and means of the processing of that personal data.

1.3 I use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, I will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, "I" refers to Garry Cosgrove. For more information about me, see Section 12.

2. Credit

2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3. The personal data that we collect

3.1 In this Section 3 I have set out the general categories of personal data that I process.

3.2 I may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you.

3.3 I may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Squarespace analytics tracking system.

4. Purposes of processing and legal bases

4.1 In this Section 4, I have set out the purposes for which I may process personal data and the legal bases of the processing.

4.2 Operations - I may process your personal data for the purposes of operating this website

4.3 Relationships and communications - I may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is my legitimate interests, namely communications with our website visitors, the maintenance of relationships, and the proper administration of our website.

4.4 Research and analysis - I may process usage for the purposes of researching and analysing the use of my website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

4.5 Record keeping - I may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this polic.

4.6 Security - I may process your personal data] for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

4.7 Insurance and risk management - I may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is my legitimate interests, namely the proper protection of our business against risks.

4.8 Legal claims - I may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is my legitimate interests, namely the protection and assertion of my legal rights, your legal rights and the legal rights of others.

4.9 Legal compliance and vital interests - I may also process your personal data where such processing is necessary for compliance with a legal obligation to which I am subject or in order to protect your vital interests or the vital interests of another natural person.

5. Providing your personal data to others

5.1 I may disclose your personal data to my insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.2 Your personal data held in my website will be stored on the servers of my hosting service provider Squarespace.

5.3 In addition to the specific disclosures of personal data set out in this Section 5, I may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person. I may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. International transfers of your personal data

6.1 In this Section 6, I provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).

6.2 The hosting facilities for our website are situated in the USA. The competent data protection authorities have made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain from https://www.privacyshield.gov/.

7. Retaining and deleting personal data

7.1 This Section 7 sets out my data retention policies and procedures, which are designed to help ensure that I comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 I collect and process both personal data and special categories of personal data as defined in the GDPR. This may include:

• Name
• Email
• Phone Number
• Address
• Location details Device IP address

Transfers to third countries and organisations

I do not transfer your personal data to third countries or international organisations.

I retain your personal data unless you ask me to delete it.

My Retention and Disposal Policy (copy available on request) details how long I hold data for and how I dispose of it when it no longer needs to be held. I will delete or anonymise your information at your request unless:

• There is an unresolved issue, such as claim or dispute
• I am legally required to
• There are overriding legitimate business interests, including but not limited to fraud prevention and protecting customers safety and security

7.4 Notwithstanding the other provisions of this Section 7, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Your rights

8.1 In this Section 8, I have listed the rights that you have under data protection law.

8.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that I transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

9. Cookie Policy

9.1 This website uses cookies and similar technologies, which are small files or short texts that are downloaded to a device when a visitor accesses a website or app. For information about how to see the cookies placed on your device, see Squarespace Cookie Policy.

• These functional and required cookies are always used as they allow Squarespace, our hosting platform, to securely serve this website to you.

• These analytics and performance cookies are only used on this website as described below if you confirm our cookie banner. I use analytics cookies to gain insight into website traffic, website activity and other data.

9.2. Analytics

This website uses Squarespace Analytics and collects personal data that serve as the basis for our website analytics. This includes:
• Information about your browser, your network and your device
• Web pages that you accessed before visiting this website
• Your IP address

This information may also include details about your use of this website, including:

• Clicks
• Internal links
• Pages visited
• Scroll
• Searches
• Time stamp

I share this information with Squarespace, our website analytics provider, to learn more about the traffic and activity on this website.

10. Managing cookies

10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

10.2 Blocking all cookies will have a negative impact upon the usability of many websites.

10.3 If you block cookies, you will not be able to use all the features on our website.

10.4 Fonts

This website uses font files from Google Fonts and Adobe Fonts. In order to display this website correctly to you, servers on which the font files are stored may receive personal data about you. This includes:

• Information about your browser, network, or device
• Your IP address

11. Amendments

11.1 I may update this policy from time to time by publishing a new version on our website.

11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

11.3 I may notify you of significant changes to this policy by email.

12. My details

12.1 This website is owned and operated by

Garry Cosgrove
6 Half Moon Bay Villas
Half Moon Bay
Basseterre
St Kitts & Nevis

12.4 You can contact me:

(a) by post, to the postal address given above;
(b) using our website contact form