Privacy Policy
Last Updated: 25th October 2024

This Data Privacy Statement will be reviewed from time to time to take into account changes in the law and the experience of the notice in practice. This policy explains the what, how, and why of the information we collect when you visit one of our pages, or when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell lists or email addresses.
If you have any queries in relation to this Data Privacy Statement, or if you have any concerns or comments, or if you want to update, delete, or change any personal information we hold, or as to how your data is processed, please email: privacy@spiritualhorticulturalist.ie
1. About the business ‘Elaine O’Mullane Spiritual Horticulturalist’
Elaine O’Mullane Spiritual Horticulturalist is a registered company name (Company Registration Number: 695916). Elaine works with people to increase their hope, possibility, and support during difficult and tough times. Transformation through Collaboration are key to her vision of personal growth and wellbeing. 
These definitions should help you understand this policy. 
When we say ‘we, us, our’, we are referring to the registered company ‘Elaine O’Mullane Spiritual Horticulturalist’. 
When we say ‘client’ we are referring to the person or entity that is registered with us to use the Services. 
When we say “you,” we are referring either to a ‘client’ or to some other person who visits our website. 
We provide online platforms that you may use to connect with us or stay in contact with others. These platforms allow for creating, sending messages or other information for the benefit of our clients (the “Services”).

We offer the Services on at least our website www.spiritualhorticulturalist.ie. This Privacy Policy applies to this specific website, as well as any other sites or mobile applications owned or operated by us (each a “Website” and together with the “Websites”). The “Websites” include the Websites themselves, and any web pages, interactive features, applications, widgets, blogs, social networks, social network “tabs,” or other online, mobile, or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device, or other technology, manner or means.
2. About this Privacy Policy
We have created this Data Privacy Statement as the controller of personal data for visitors to this website, for prospects, clients, and former clients. This notice aims to demonstrate our firm commitment to privacy and to inform people dealing with us about the information we collect and process in connection with such interaction.
This privacy statement sets out an explanation of what personal data about you we process, why we process your personal data, with whom your personal data is shared and a description of your rights with respect to your personal data.
3. What Personal Data do we Process?
We need to keep and process certain personal data about you to manage our business, for management purposes, to comply with our legal obligations and, where necessary, to protect our legitimate business interests. We will collect and process personal data from you during your visit on this website, during our contractual relationship and following the termination of our contractual relationship. Personal data is normally obtained directly from you voluntarily.
‘Personal Information’ means any information that identifies or can be used to identify you directly or indirectly, including, but not limited to, first and last name, date of birth, email address and IP address.
4. How do we use your data?
The information we hold, and process will be used for management and administrative purposes. We keep it and use it to enable us to run our business, manage our contractual relationship with you effectively, lawfully, and appropriately and protect your rights and interests as well as comply with legal obligations, pursue our legitimate interests, and protect ourselves in the event of legal proceedings against the company.
The uses we make of each category of your personal data, together with the lawful basis we rely on for those uses are set out in more details below.
Where there is a need to process your data for a purpose other than those set out in the policy or otherwise outlined to you, we will inform you of this.
5. How is your personal data shared?
Your personal data may be disclosed to third parties where we are legally obliged to do so. For example, we pass on certain information to our accountant to fulfil our legal obligations.
More detailed information on how we share your personal data is set out below.
6. Will your Personal Data be transferred abroad?
The ‘Elaine O’Mullane Spiritual Horticulturalist’ website is hosted on Let’s EncryptLet’s Encrypt is a service provided by Internet Security Research Group, a California (United States) Non-profit Public Benefit Corporation. Let’s encrypt does not sell your data or information. This includes Relying Party, Subscriber, and Visitor data and information.
The transfer of personal data is explained in more detail below.
7. How long do we keep your personal data?
Any personal data processed about you on this website is retained in accordance with our record retention policy:
• Website logs and emails: 6 months or less
Invoices: 6 years + current financial year
Marketing opt-ins: until you opt-out
Telephone/WhatsApp contact: Until the end of our relationship or on request.
Eventbrite: Data will be deleted within 1 month once the event has taken place.
8. What happens if you do not provide us with your personal data?
In some cases, you may decline to provide us with your personal data. If we believe that we require relevant personal data to effectively and properly manage our contractual relationship, we may not be able to continue our relationship with you.
9. Will you be subject to profiling and automated decision making?
You will not be subject to profiling or automated decision making.
10. What are your rights under the data protection laws?
You have the following rights under data protection law:
Information Request: the right to receive a copy of and/or access the personal data that we hold about you, together with other information about our processing of that personal data.
Update Data: the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information, you may request that we update the information such that it is complete.
Data Deletion: the right, in certain circumstances, to request that we erase your personal data in line with legal requirements.
Restrict Processing/ Object to Processing: the right, in certain circumstances, to request that we no longer process your personal data for purposes, or object to our use of your personal data or the way in which we process it.
Data Portability: the right, in certain circumstances, to transfer your personal data to another organisation.
Review Automated Decisions: the right to object to automated decision making and/or profiling.
File a Complaint: the right to complain to the Data Protection Commissioner
Please note that your ability to exercise these rights may be subject to certain conditions.
11. Details of Processing Activities
As a visitor to the website
The transfer of the website content between your browser and our server is secured through TLS X. 509 Encryption. You can obtain more information about Let’s Encrypt here.
Personal data processed
Your IP address- Let’s Encrypt records your IP address, browser, and operating system in temporary server log files. They do not use data from OCSP requests to build profiles or identify individuals. Temporary server logs are used for operational purposes only and are normally deleted in less than seven days.
The page viewed.
The time the page was viewed.
The browser you used to view the page.
We do not cross reference the log with the enquiry, but we reserve the right to do so should we be concerned about the security of our operations.
Purpose and lawful basis for processing of your personal data
The purpose for processing your personal data includes:
To provide access to and enhance your website experience.
To analyse user behaviour and site interaction to improve content and services offered on our website.
To comply with legal obligations.
For marketing and promotional purposes with explicit consent.
The lawful basis for processing your personal data includes:
Legitimate interest: Necessary to improve website functionality, security, and performance, creating a better user experience and allows us to understand visitor needs, optimize content, and make informed improvements.
Legal Obligation – Processing required to protect against data breaches, fraud, or other unlawful activities.
Consent – Where applicable, visitors will have given explicit consent for marketing cookies and promotional tracking.
Sharing of personal data
Our website infrastructure provider is Let’s Encrypt, which is based in California in the United States.Therefore, your personal data may be collected from or transferred to jurisdictions where the service providers store or process data, including the United States. 
These jurisdictions may not provide the same level of data protection as the EEA. Let’s Encrypt have entered into data processing agreements using the European Commission-approved Standard Contractual Clauses, and/or by using other safeguards approved by the European Commission. Full details of the Let’s Encrypt Privacy Policy may be found here
When you make an enquiry via a form on this website
The transfer of the website content between your browser and our server is secured through TLS X. 509 encryption. You can verify by clicking the padlock on your browser.
We collect:
your name and email address
comments supplied in the form.
the time of the enquiry
country
Purpose and lawful basis for processing of your personal data
Contractual obligations: We collect the information so we can manage your enquiry.
To provide information to representatives and advisors, including legal representatives and accountants, to help us comply with legal, accounting, or security requirements.
To prosecute and defend a court, arbitration, or similar legal proceeding.
To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Sharing of personal data
The enquiry is handled by the owner of the business- Elaine O’Mullane.
Our website infrastructure provider is Let’s Encrypt, which is based in California in the United States.Therefore, your personal data may be collected from or transferred to jurisdictions where the service providers store or process data, including the United States. 
These jurisdictions may not provide the same level of data protection as the EEA. Let’s Encrypt have entered into data processing agreements using the European Commission-approved Standard Contractual Clauses, and/or by using other safeguards approved by the European Commission. Full details of the Let’s Encrypt Privacy Policy may be found here
On occasion we organise events using facilitators. We use Eventbrite.ie to manage these events (please click here for more details on how Eventbrite manages your personal data).
Personal data processed:
The data that is collected include: 
your name, email address
bank details if there is a charge for the service.
the service you purchase on Eventbrite.
Purpose and lawful basis for processing of your personal data
To organise events: Eventbrite allow us, the organizer, to use their email tools to contact consumers for events. Clients may receive emails from the Eventbrite system that originate with us and that they send on our behalf. If you registered for an event on the Eventbrite services, your email address is available to the Organizer.
Contractual obligations: We collect the information so we can handle your account to keep your information up to date. 
What will happen if the personal data is not provided?
You will not be able to register your attendance.
Sharing of personal data
See Section 5-6 of the Eventbrite Policy document for information on how Eventbrite shares personal data, click here.
When you make an enquiry via telephone or Business WhatsApp
Clients may avail of messaging to make contact, avail of services, and organise appointments. 
Personal data processed:
We collect the following information:
Your name
Contact information (such as phone number or WhatsApp ID)
Details relevant to your enquiry
Purpose and lawful basis for processing of your personal data
The legal basis for processing your personal data is legitimate interest under GDPR, as it is necessary for us to respond to and manage your enquiry.
Sharing of personal data
We do not share your personal information with third parties unless it is required by law or with your explicit consent. WhatsApp messages and calls are end-to-end encrypted. No one else, not even WhatsApp, can read or listen to them. Disappearing Messages function on Business WhatsApp is activated to disappear all new chat messages in 90 days from initial contact. The WhatsApp policy on sharing data is available to read here
Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you or people in your community, then we will notify you within 48hrs and later report the action we took in response.

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Cookies

How we use your information
This privacy notice tells you what to expect when we collect personal information. It applies to information we collect about:
Visitors to our websites.
People who use our services, e.g. enquire about or purchase products or services.
Visitors to our websites
When someone visits this site, we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Below explains the cookies we use and why. Each of these cookies is strictly necessary for the continued operation of this website.

Cookie Provider
Google Analytics
Purpose
Google Analytics is a third-party tool which has been configured to only collect anonymised data for the use of providing diagnostic information about this website’s stability.
More information
Click here for further information

Cookie Provider
Let’s Encrypt
Purpose
If a browser makes an OCSP request, Let’s encrypt servers will automatically record the IP address, browser, and operating system in temporary server log files. They do not use data from OCSP requests to build profiles or identify individuals. Temporary server logs are used for operational purposes only and are normally deleted in less than seven days
More information
Click here for further information

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org orwww.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
Use of cookies by 3rd Parties
Social media platforms and widgets. Our Websites include social media options, such as links to LinkedIn, Facebook, Instagram, and Threads. Social media features and widgets are hosted by a third party. We maintain presences on social media platforms including LinkedIn, Facebook, Instagram, and Threads. 
NOTE: Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them. We encourage you to carefully read the privacy policy of any Website you visit.
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