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Privacy Policy

Last updated: [insert date]

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Lunar Grove Sound respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, who it may be shared with, and the rights you have over your personal information.

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This policy applies when you:

  • visit the Lunar Grove Sound website;

  • contact us with an enquiry;

  • book or attend a sound bath, meditation session or private event;

  • join our mailing list;

  • interact with us through social media; or

  • work with us as a venue, supplier or business contact.

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Lunar Grove Sound processes personal information in accordance with UK data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018.

This template should be updated to reflect the website, booking system, payment provider, mailing platform and analytics tools actually used by Lunar Grove Sound before it is published.

1. Who we are

For the purposes of data protection law, Lunar Grove Sound is the data controller responsible for deciding how and why your personal information is used.

 

Business name: Lunar Grove Sound
Business owner: Kerry [surname]
Business address: [insert business or correspondence address]
Email: [insert email address]
Telephone: [insert telephone number]
ICO registration number: [insert if applicable]

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You can contact Lunar Grove Sound using these details if you have any questions about this policy or how your information is handled.

2. The information we may collect

The personal information we collect will depend on how you interact with us.

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Contact and identification information

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This may include:

  • your name;

  • email address;

  • telephone number;

  • postal address, where required;

  • emergency contact details, where appropriate; and

  • the name of the person making a group booking.

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Booking and payment information

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This may include:

  • the session or event you have booked;

  • booking dates and attendance records;

  • the number and names of attendees;

  • payment status;

  • transaction references;

  • discount or gift voucher information;

  • cancellation or transfer requests; and

  • correspondence relating to your booking.

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Payments may be processed by an independent payment provider. Lunar Grove Sound will not usually receive or store your full debit or credit card details.

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Health, accessibility and participation information

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You may choose to tell us about:

  • medical conditions relevant to your participation;

  • pregnancy;

  • sound sensitivities;

  • mobility or accessibility requirements;

  • implanted medical devices;

  • allergies or other safety concerns; and

  • adjustments you may need to attend a session.

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Health information is considered special category personal data and receives additional protection under UK data protection law.

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Please only provide information that is relevant to your safe participation. Lunar Grove Sound is not a medical service and does not require a complete medical history.

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Enquiries and correspondence

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We may collect information contained in:

  • website contact forms;

  • emails;

  • telephone calls;

  • social media messages;

  • feedback forms;

  • complaints; and

  • reviews or testimonials.

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Marketing preferences

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This may include:

  • whether you have chosen to receive emails;

  • the topics or events you are interested in;

  • when and how you gave consent; and

  • whether you have unsubscribed.

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Website and technical information

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When you use the website, certain technical information may be collected automatically, such as:

  • your IP address;

  • browser and device type;

  • approximate location;

  • pages visited;

  • the date and time of your visit;

  • referring website;

  • cookie preferences; and

  • interactions with the website.

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This information may be collected through cookies, analytics tools and the website hosting platform.

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Photographs and recordings

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Where photographs, video or audio are taken at an event, we may collect your image or voice.

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You will be informed where event photography or recording is planned. We will seek appropriate permission before using identifiable images for promotional purposes.

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Information relating to children

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Where a child or young person attends an eligible session, we may collect:

  • their name and age;

  • the name and contact details of their parent or guardian;

  • emergency contact information;

  • relevant accessibility or safety information; and

  • parental or guardian permission.

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We will only collect information about children when it is reasonably necessary and will treat it with particular care. Children’s personal data requires additional protection under UK data protection law.

3. How we collect your information

We may collect personal information directly from you when you:

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  • complete a contact or booking form;

  • make a payment;

  • join a mailing list;

  • contact us by email, telephone or social media;

  • attend a session;

  • complete a health, accessibility or consent form;

  • leave a review;

  • enter a competition; or

  • provide information in person.

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We may also receive information from:

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  • a person making a group booking on your behalf;

  • an event organiser or retreat host;

  • a booking or ticketing platform;

  • a payment provider;

  • a venue;

  • website analytics and cookie tools; or

  • social media platforms when you interact with our pages.

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Where someone books on behalf of another person, they should ensure they have permission to provide that person’s information.

4. How and why we use your information

We use personal information only when we have a lawful reason to do so.

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To respond to enquiries

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We use your name, contact details and the contents of your enquiry to respond to you and provide the information you have requested.

Our lawful basis is usually legitimate interests, as it is reasonable for us to respond when you contact us.

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Where your enquiry relates to a possible booking, we may also process the information in order to take steps at your request before entering into a contract.

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To manage bookings and provide services

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We use your information to:

  • confirm and administer bookings;

  • take payment;

  • send joining instructions;

  • tell you about changes or cancellations;

  • manage transfers and refunds;

  • provide private or group sessions; and

  • keep an appropriate record of the service provided.

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Our lawful basis is contract, because this information is needed to fulfil your booking or take steps before a booking is made.

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To support health, safety and accessibility

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We may use information you voluntarily provide to:

  • consider whether reasonable adjustments are needed;

  • help you participate safely;

  • respond appropriately in an emergency; and

  • identify whether you should seek professional medical advice before attending.

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Where this includes health information, we will identify both a lawful basis under Article 6 of the UK GDPR and a separate condition for processing special category data.

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Depending on the circumstances, this may include your explicit consent. You may withdraw consent, although this will not affect processing that has already taken place lawfully.

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To process payments and maintain financial records

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We use booking and transaction information to:

  • process payments and refunds;

  • issue receipts;

  • prevent fraud; and

  • maintain accounting and tax records.

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Our lawful bases may include contract and legal obligation.

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To send marketing communications

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Where you have chosen to receive news and updates, we may send you information about:

  • upcoming sound baths;

  • new venues;

  • private sessions;

  • retreats;

  • seasonal events; and

  • other Lunar Grove Sound services.

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For email and text marketing to individual customers, we will generally rely on your consent where required.

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Electronic marketing is also subject to the Privacy and Electronic Communications Regulations. Where those regulations require consent, the ICO advises that consent will normally also be the appropriate UK GDPR lawful basis.

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You can unsubscribe at any time by:

  • selecting the unsubscribe link in an email;

  • replying to a message;

  • contacting Lunar Grove Sound; or

  • updating your preferences where this facility is available.

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Withdrawing from marketing will not affect essential messages relating to an existing booking.

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To improve our website and services

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We may use feedback, website statistics and aggregated information to:

  • understand how people use the website;

  • improve website accessibility and performance;

  • develop new services;

  • assess the popularity of events; and

  • improve the customer experience.

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Our lawful basis may be legitimate interests, provided these interests do not override your rights and freedoms.

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Where non-essential cookies or analytics technologies require consent, they will not be activated until you have made your choice.

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To manage reviews and testimonials

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We may use feedback to improve our services.

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We will seek permission before publishing a testimonial in a way that identifies you. You can ask us to remove a published testimonial, although copies that have already been printed or shared may not always be recoverable.

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To protect our business and comply with the law

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We may use or retain information where reasonably necessary to:

  • establish or defend a legal claim;

  • deal with a complaint;

  • comply with insurance requirements;

  • respond to lawful requests from public authorities;

  • prevent fraud or misuse; and

  • meet legal, regulatory, tax or accounting obligations.

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Our lawful bases may include legal obligation and legitimate interests.

5. Our lawful bases

Depending on the purpose, Lunar Grove Sound may rely on one or more of the following lawful bases:

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Contract

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The information is needed to take steps before a booking or to provide a service you have booked.

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Legal obligation

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The information is needed to comply with a legal requirement, such as maintaining appropriate financial records.

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Legitimate interests

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The information is used for a reasonable business purpose that you would expect and that does not unfairly affect your rights.

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Where we rely on legitimate interests, we consider:

  1. why the information is needed;

  2. whether the use is necessary; and

  3. whether your rights and interests outweigh our business need.

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The ICO advises that legitimate interests should generally be used where the processing is reasonably expected, necessary and has a limited effect on the person’s privacy.

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Consent

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You have freely given clear permission for a particular use, such as receiving marketing emails or allowing an identifiable photograph to be used.

Consent must involve a genuine choice and a clear positive action, and it must be possible to withdraw it.

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Vital interests

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In a genuine emergency, we may use or share information where necessary to protect someone’s life.

6. Who we may share your information with

We do not sell your personal information.

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We may share limited information with trusted organisations that help us operate the business, including:

  • website hosting providers;

  • online booking or ticketing platforms;

  • payment processors;

  • email and newsletter providers;

  • accounting or bookkeeping services;

  • cloud storage and administration providers;

  • event venues;

  • retreat or event organisers;

  • IT and technical support providers;

  • insurers;

  • professional advisers; and

  • government, regulatory or law enforcement bodies where legally required.

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Examples may include:

  • Website platform: Wix

  • Booking provider: Wix

  • Payment provider: Wix

  • Email platform: Mailchimp

  • Analytics provider: Google Analytics

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These organisations may process information on our behalf or act as independent data controllers under their own privacy policies.

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We only share information that is reasonably necessary for the relevant purpose. When another organisation processes information on our behalf, we take reasonable steps to ensure appropriate contractual and security arrangements are in place.

7. International transfers

Some service providers may store or process personal information outside the United Kingdom.

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Where information is transferred internationally, we will take reasonable steps to ensure that it remains appropriately protected. This may include relying on:

  • UK adequacy regulations;

  • an approved international data transfer agreement;

  • the UK Addendum to approved standard contractual clauses; or

  • another lawful transfer safeguard.

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The exact arrangements will depend on the platforms used by Lunar Grove Sound.

8. How long we keep your information

We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, including any legal, accounting, insurance or reporting requirements.

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The UK GDPR does not set one universal retention period. Organisations must choose and justify periods based on why the information is needed.

Indicative retention periods may include:

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Type of information and suggested retention period:

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  • General enquiries that do not lead to a booking- Up to 12 months

  • Booking and attendance records - Up to 6 years after the relevant financial year

  • Payment and accounting records - Usually 6 years after the relevant financial year

  • Health and accessibility information - Until the session is complete, or for a limited period where needed for an incident, insurance matter or ongoing booking

  • Accident or incident records - In accordance with legal and insurance requirements

  • Marketing subscription records - Until you unsubscribe, plus a limited suppression record to respect your choice

  • Records showing when consent was given or withdrawn - For as long as needed to demonstrate compliance

  • Complaints and related correspondence - Usually up to 6 years, depending on the nature of the matter

  • Website analytics - According to the settings of the relevant analytics platform

  • Photographs and marketing material - Until consent is withdrawn or the material is no longer needed, subject to practical limitations

These periods should be reviewed and adjusted to match Lunar Grove Sound’s actual business, insurance and accounting requirements.

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When information is no longer required, it will be securely deleted, destroyed or anonymised.

9. How we protect your information

We take reasonable technical and organisational measures to protect personal information from:

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  • unauthorised access;

  • accidental loss;

  • misuse;

  • alteration;

  • disclosure; and

  • destruction.

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Measures may include:

  • password-protected accounts;

  • multi-factor authentication where available;

  • secure website connections;

  • access controls;

  • trusted payment processors;

  • secure devices;

  • software updates;

  • restricted access to sensitive information; and

  • secure disposal of paper and electronic records.

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No internet or storage system can be guaranteed to be completely secure. If a personal data breach occurs, we will assess it and notify the Information Commissioner’s Office and affected individuals where the law requires us to do so.

10. Cookies

Cookies are small files stored on your device when you visit a website.

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The Lunar Grove Sound website may use:

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Strictly necessary cookies

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These are required for essential functions such as:

  • website security;

  • booking forms;

  • payment processes;

  • remembering cookie preferences; and

  • keeping the website working correctly.

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These cookies do not usually require consent.

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Analytics cookies

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These help us understand how visitors use the website, such as which pages are viewed and how people arrive at the site.

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Functionality cookies

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These may remember settings or support embedded features.

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Marketing cookies

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These may be used to measure advertising, track campaigns or provide more relevant content.

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Visitors must be told about the cookies a website uses. Non-essential cookies generally require the visitor’s agreement before they are placed or accessed.

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The website should include a suitable cookie consent tool and, where necessary, a separate Cookie Policy listing the specific cookies used.

You can also manage cookies through your browser settings, although disabling essential cookies may affect website functionality.

11. Social media

Lunar Grove Sound may use platforms such as Facebook and Instagram.

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When you interact with us through a social media platform, that platform may collect and use your information according to its own privacy policy. Lunar Grove Sound does not control how social media providers process information through their wider services.

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Please avoid sharing sensitive personal or health information publicly in comments. Contact us privately where information relates to a booking, accessibility need or health concern.

12. Links to other websites

The Lunar Grove Sound website may include links to third-party websites, booking platforms or social media pages.

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This Privacy Policy does not cover the way those organisations use your information. You should review their privacy information before providing personal details.

13. Your data protection rights

Depending on the circumstances, you may have the right to:

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Be informed

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You have the right to clear information about how your personal information is collected and used.

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Access your information

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You can ask for a copy of the personal information Lunar Grove Sound holds about you.

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Correct inaccurate information

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You can ask us to correct or complete information that is inaccurate or incomplete.

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Request deletion

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You may ask us to delete your information in certain circumstances. This right does not always apply, particularly where information must be retained for legal, financial or contractual reasons.

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Restrict processing

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You may ask us to limit the way we use your information in certain circumstances.

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Object to processing

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You may object to certain uses based on legitimate interests. You have an absolute right to object to the use of your personal information for direct marketing.

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Data portability

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In some circumstances, you may ask for information you provided to be transferred to you or another organisation in a commonly used, machine-readable format.

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Withdraw consent

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Where we rely on consent, you can withdraw it at any time. Withdrawal will not affect the lawfulness of processing that took place before consent was withdrawn.

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Rights relating to automated decisions

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You may have rights where a significant decision is made entirely through automated processing.

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Lunar Grove Sound does not currently intend to make decisions about customers using solely automated processes.

The ICO identifies access, objection, information and erasure among the principal rights small businesses are likely to encounter.

14. Exercising your rights

To exercise a data protection right, contact:

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Email: [insert email address]
Postal address: [insert correspondence address]

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Please describe your request clearly and provide enough information for us to identify the relevant records.

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We may need to confirm your identity before releasing or changing personal information.

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There is usually no charge for making a request. However, a reasonable fee may be permitted where a request is manifestly unfounded, excessive or repetitive, or we may be permitted to refuse it.

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We will respond within the time required by data protection law.

15. Complaints

Please contact Lunar Grove Sound first if you are concerned about the way your information has been handled. We will aim to resolve your concern fairly and promptly.

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You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection.

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The current contact and complaints details should be obtained directly from the ICO website.

16. Changes to this Privacy Policy

We may update this policy when:

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  • our services change;

  • we introduce a new booking or marketing platform;

  • the website changes;

  • our data handling practices change; or

  • legal requirements are updated.

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The latest version will be published on the website with a revised “last updated” date.

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Where a change significantly affects how we use information already collected, we will take reasonable steps to bring it to the attention of the people affected.

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The ICO recommends reviewing privacy information regularly and making it easily available when personal information is first collected.

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