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Privacy and Cookie Statement

1. General
1.1 This privacy and cookie policy (hereinafter referred to as; the “Privacy & Cookie Policy”) applies to anyone who visits, views, listens to, and/or uses: 
(a) the website with domain name sarahgrete.com (hereinafter referred to as; the "Website") which is owned by Sarah Al-Bashtali Advisory (hereinafter referred to as; the "Owner”); or 
(b) the images, video recordings, text, and other content placed on Instagram with the following social media handle: @sarahgrete;
(c) the text, images, and other content included in the emails of the Owner; or
(d) any other content created by the Owner and placed on any other social media channels or digital platforms, 
hereinafter collectively referred to as; the “Platforms”.
1.2 The terms "You" and "Your" refer to anyone who visits, views, listens to, and/or uses any of the Platforms. 
1.3 The Privacy & Cookie Policy outlines how the Owner may collect, use, and share information about You when using any of the Platforms, together with products and services the Owner offers from time to time on any of the Platforms. The Privacy & Cookie Policy describes both the Owner’s and Your legal rights and responsibilities with regards to the information contained on and collected by any of the Platforms, including information that identifies You, such as Your name, contact information, location, email address, search tendencies, and how You use any of the Platforms.
1.4 This Privacy & Cookie Policy does not apply to or in any way cover the collection and/or use of Your personal data by third-party websites or programs, such as search engines, payment providers, including, but not limited to, website hosts, social media platforms, or client management systems. The collection and/or use of data and information by third-party platforms and programs, such as the aforementioned, are governed by each third-party's respective privacy policy.
1.5 The Owner reserves the right to amend and modify this Privacy & Cookie Policy at any time without notice. By visiting, viewing, listening to and/or using any of the Platforms, You agree and accept to be (legally) bound by this Privacy & Cookie Policy along with the disclaimer applicable to the Platforms, which You can find here (hereinafter referred to as; the “Disclaimer”).

2. Website terms
By visiting, viewing and/or using the Website, You agree and accept to be (legally) bound by this Privacy & Cookie Policy along with the terms and conditions applicable to the Website, which You can find here (hereinafter referred to as; the “Terms”).

3. Your age
3.1 All information and content, including, but not limited to, any products and/or services provided on the Platforms, are aimed at adults. The Owner does not knowingly collect and does not envisage collecting personal data from individual persons below the age of 18.
3.2 The Owner makes no representation that the information, including, but not limited to, any products and/or services, on any of the Platforms, is available or appropriate for use by individual persons below the age of 18. 
3.3 The Platforms are not intended to be visited, viewed, listened to, or used by children without the involvement and approval of (one of) Your parent(s) or legal guardian(s). If You are younger than the age of 13 years, the Owner does not permit You to provide Your personal data on any of the Platforms. 
3.4 If You are the age of 13 years or older but younger than the age of 18 years, You may only provide Your personal data on any of the Platforms after You have been given the consent (one of) Your parent(s) or legal guardian(s), including consent to this Privacy & Cookie Policy, the Disclaimer, and the Terms (if You visit, view and/or use the Website).


4. Collection of Your personal data
4.1 When You visit, view, listen to, and/or use any of the Platforms, You may provide certain personal data, including but not limited to:
(a) Your (full) name;
(b) Your phone number;
(c) Your email address;
(d) Your date of birth and/or age;
(e) Your photo, video footage of You, and/or any other material containing your likeness;
(f) any material containing Your voice;
(g) Your Internet Protocol (IP) address (which is considered personal data only when it could identify You in conjunction with other personal data);
(h) Your (home, mailing and/or business) address;
(i) Your billing address; and/or 
(j) Your credit or debit card information.
4.2 Events and circumstances in which the Owner may collect Your personal data include, but are not limited to, the following:
(a) Submitting (contact) forms & downloads: When You submit forms or download a product or service on any of the Platforms, certain personal data about You may be collected, including, but not limited to, Your (full) name, location, and email address.
(b) Subscribing to an email list: When You subscribe to the Owner's email list to receive emails from the Owner, certain personal data about You may be collected, including, but not limited to, Your (full) name and email address.
(c) Performance of a contract: When You enter into a contract with the Owner, either by (digitally) singing a contract or accepting the applicable terms of use or service, the Owner may require and/or use certain personal data to fulfil its obligations under the contract and comply with the terms of the contract and applicable laws.
(d) Purchasing services or products: When You purchase a product or service from any of the Platforms, certain personal data may be required to fulfil Your requests, such as names, credit card numbers/expirations/security codes, and billing information and addresses, which are processed through a third-party payment program. Your personal data will not intentionally be shared with any third party other than the third-party programs responsible for processing Your payment to the Owner.

5. Use of personal data
5.1 Your personal data may be used to: 
(a) personalise Your experience;
(b) improve any of the Platforms and/or the products and/or services offered by the Owner to better serve You;
(c) provide customer service support and manage individual accounts; 
(d) efficiently process Your requests or transactions;
(e) elicit reviews of services or products;
(f) grant You access to specific content and services online;
(g) educate the Owner on the Platforms’ visitors’, viewers’, listeners’ and users’ tendencies and preferences;
(h) provide You offers and/or promotions; and/or 
(i) to follow up with You through correspondence, such as via email, including, but not limited to, newsletters, promotional emails, and product attachments. 
5.2 The Owner may also use Your personal data to provide You offers and promotions from its partners and/or its affiliates in exchange for a commission without additional cost to You.
5.3 The Owner does not sell any of Your personal data to third parties and has never sold Your personal data. The Owner does not intend to share, trade, or sell Your personal data in the future either.

6. Disclosure to third parties
6.1 As a general rule, the Owner does not disclose Your personal data to or share Your personal data with third parties without Your consent, except in the following cases and circumstances:
(a) The Owner may disclose Your information to its trusted third parties that work with the Owner, such as the Owner’s website hosting partners, email marketing service providers, other service providers that assist in the operation of the Website, and any other third parties the Owner relies upon to provide You products and services offered on any of the Platforms.
(b) The Owner may disclose Your information in order to comply with applicable laws and/or regulations related to intellectual property right infringement lawsuits or any other legal claims or investigations related to any of the Platforms.

7. Analytics
7.1 The Website collects certain information about You automatically through log data and Google Analytics. Log data is information about Your device's Internet Protocol Address (Your "IP" address), browser information, Your internet service provider's information, and Your operating system. 
7.2 Google Analytics collects information about Your location, the pages You visit, browsing history, the equipment You use to access the Website, traffic patterns, and other general patterns related to Your visit to, view of and/or use of the Website.
7.3 The aforementioned information is used to analyse the Platforms’ statistics related to user behaviour and interests, improve the performance of the Platforms and Your use of the Platforms, and further enhance the products and services offered to You. 

8. Cookies 
8.1 The Website uses cookies to facilitate Your use of the Website. Cookies are data files with small amounts of data, including a unique anonymous identifier that a website sends to Your device's hard drive when You are viewing the Website. The Website automatically collects non-personal information, including, but not limited to: 
(a) Your Internet Protocol (IP) address;
(b) the domain name You requested;
(c) the pages You have visited, viewed or used;
(d) Your geographic location;
(e) the website which referred you to the Website;
(f) the date and time of Your visit, viewing or use;
(g) the length of Your session;
(h) the number of times You have visited, viewed or used the Website within a given time period;
(i) the operating system which Your computer uses; and
(j) the technical capabilities of Your web browser.
8.2 When You leave a comment on the Website, You may opt-in to have Your name, email address, and website saved in cookies. These are used for Your convenience so that You do not have to fill out Your details again when using the Website. 
8.3 The Owner may use cookies for various reasons, including, but not limited to, optimizing and personalizing Your browsing experience, checking the Website's analytics, and saving Your settings and preferences for future use.
8.4 This information is only collected to better facilitate You and understand Your user experience on the Website. You have the option of turning off cookies on Your device if You want to do so. If You choose to do that, You may not be able to view all the features and content of the Website.

9. Web beacons
The Platforms, other than the Website, and other platforms of third parties, such as social media platforms, may use their own cookies, web beacons, and other mechanisms to receive and collect information from the Website for the purpose of providing target advertisements. 

10. Third-party information 
10.1 Any content on any of the Platforms may include embedded content, such as text, images, videos, etc. Embedded content from third-party platforms acts in the same way as if the visitor has visited those third-party platforms. 
10.2 Third-party platforms may use cookies, collect data about You, embed additional third-party tracking, and monitor Your interaction with the embedded content, including, but not limited to, tracing Your interaction with the content embedded on any of the Platforms if You have an account and You are logged in to those third-party platforms.
10.3 The Owner has no control over these third parties, and they have their own privacy policies. The Owner is not responsible for the activities and practices of these third parties. As such, the Owner is not responsible or liable under any circumstances for the collection, processing, and/or the use of Your personal data by third parties and/or the third parties' compliance with their respective privacy policies. You agree that Your use of these third-party platforms is solely at Your own risk.

11. Email List 
11.1 You may subscribe to or unsubscribe from the Owner's email list. By subscribing, You agree to receive newsletters, messages, updates, promotional materials, and any other content related to any of the Platforms and the products and/or services of the Owner. When You send an email, Your email, along with your email address and responses, are saved for communication purposes with You. This information is kept confidential, and the Owner does not share, trade, or sell Your email with third parties, except as otherwise provided in the Privacy & Cookie Policy.
11.2 If You are in the European Union or in the United Kingdom and subscribe to receive any of the Owner's free products and/or services and/or purchase any products and/or services, then You will be subscribed to receive the Owner's free email newsletter once You consent to it. Please see the 'Unsubscribe' section below should You wish to "unsubscribe" and not receive any emails from the Owner.
11.3 If You are NOT within the European Union or in the United Kingdom, You may be automatically subscribed to receive the Owner's free email newsletter once You opt-in to receive any of the Owner's free products and/or services and/or purchase any products and/or services. Please see the 'Unsubscribe' section below should You wish to "unsubscribe" and not receive any emails from the Owner.

12. Unsubscribe
If You do not or no longer wish to receive communication from the Owner, You have the option to unsubscribe by clicking the "unsubscribe" link or button contained in the email at the bottom right or by contacting the Owner.

13. GDPR compliance & Your rights
13.1 If You are in the European Union or if You are in the United Kingdom, You are entitled to certain rights under the General Data Protection Regulation and the UK’s Data Protection Act 2018 (the United Kingdom’s implementation of the General Data Protection Regulation) (hereinafter collectively referred to as; the “GDPR”), as indicated in this section.
13.2 You are entitled to:
(a) withdraw any consent You have given to the Owner for the collection of Your personal data at any time (which will not make the processing carried out by the Owner before you have withdrawn the consent unlawful);
(b) request and receive from the Owner information about what personal data is collected from You by the Owner and how it is used;
(c) access Your personal data that is held by the Owner;
(d) request and receive Your personal data in a machine-readable format and have Your personal data transferred to another person (“data portability”);
(e) request the Owner to correct any of Your personal data that is incorrect, inaccurate or incomplete;
(f) request the Owner to erase Your personal data if Your personal data is not or no longer needed by the Owner or if the processing of Your personal data by the Owner is unlawful;
(g) object to the processing of Your personal data by the Owner for marketing purposes or on grounds relating to Your particular situation, including, but not limited to, for the purposes of direct marketing, scientific or historical research, profiling, statistical purposes, automated decision-making, and tasks based on the legitimate interests of the Owner or in the public interest/exercise of governmental authorities;
(h) request the Owner to restrict the processing by the Owner of Your personal data in specific cases, in which case the Owner can store Your personal data but cannot process it further; and
(i) request that computers do not make big decisions concerning You through automatic processing and are made by natural persons instead.
13.3 The Owner will respond to your requests at the latest within one month. If the Owner does not intend to comply with your request, the Owner will state the reason why.
13.4 The Owner will retain any of Your personal data that You have provided to the Owner until the earlier of:
(a) Your personal data is no longer needed for the Owner to provide You services;
(b) You requesting the Owner to delete Your personal data;
(c) the Owner finds Your personal data to be outdated;
(d) it is too costly to maintain further retention of Your personal data;
(e) the Owner’s decision to cease using its existing data providers; or
(f) the Owner discontinues its business or its services.

14. Reviewing, accessing & updating Your personal data
14.1 To exercise any of Your rights You may have under any privacy and data protection laws (such as reviewing or accessing Your personal data or making changes to Your personal data), You may contact the Owner at sarah@sarahgrete.com.
14.2 When You make a request by email, Your email request must provide adequate information that allows the Owner to verify that You are the person You claim to be or that You are authorized to represent such person about whom the Owner has collected personal data. You are required to describe Your request with enough details, such as Your first and last name and Your address, and in such a way that allows the Owner to properly understand the request and respond to it. The Owner may ask You to provide (additional) information to confirm Your identity in order to exercise Your rights. 
14.3 The Owner cannot respond to Your email request or provide You with personal data unless the Owner has first: (i) verified Your identity and/or Your authority to make such a request; and (ii) confirmed that the personal data relates to You. 
14.4 The Owner will: 
(a) in any case that You have and are exercising rights under the GDPR, respond to Your email request without undue delay but at the latest within one month of receipt by the Owner of a request from You, which may be extended by two further months when necessary, taking into account the complexity of Your request and the number of Your requests, in which case You will be provided notice of such extension together with the reasons for such delay. The Owner will provide reasons if the Owner does not intend to comply with any of Your requests regarding Your personal data.
(b) in any other case, attempt to respond to Your email request within 30 days of receipt of Your request.

15. Security
15.1 The Owner takes all the necessary security measures appropriate to secure your personal data provided to the Owner. The Owner strives to follow generally commercial industry standards to protect Your personal data submitted to the Owner automatically and voluntarily. 
15.2 Notwithstanding the previous paragraph, no transmission over the internet is completely secure, and the Owner does not warrant, guarantee or promise in any way the absolute security of Your personal data. 
15.3 When You make a purchase through any means on any of the Website, You are directed to a third-party vendor to complete the transaction. Any and all information You provide during the checkout process is not stored on the Website but instead provided to a third-party vendor that completes the transaction.
15.4 By visiting, viewing and/or using the Website, You agree to hold the Owner harmless for any and all security breaches and any and all unauthorized use of Your personal data by third parties. The Owner cannot be held responsible for any disclosure of Your personal data through any of the Website without the Owner's knowledge and consent.
 

16. Updates & amendments 
16.1 This Privacy & Cookie Policy is effective as of 25.05.2023 and was last updated on 25.05.2023. 
16.2 The Owner reserves the right to amend and modify this Privacy & Cookie Policy at its sole discretion at any time without notice. By visiting, viewing, listening to and/or using any of the Platforms, You accept any amendments and modifications to this Privacy & Cookie Policy by or on behalf of the Owner. 
16.3 It is Your responsibility to regularly check the Website for updates and amendments. If the Owner makes any material changes or updates to the Privacy Policy, the Owner will notify You by email at the email address that You have most recently provided to the Owner or by posting a notice on the Website.
16.4 Your continued use of any of the Platforms after the publication of any changes to this Privacy & Cookie Policy will constitute Your acceptance of those changes and updates unconditionally. You must not visit, view, listen to and/or use any of the Platforms if You will not adhere to this Privacy & Cookie Policy or do not want to be bound by this Privacy & Cookie Policy.

17. Contact
For any questions, requests and/or comments regarding this Privacy & Cookie Policy or Your personal data, please contact the Owner at sarah@sarahgrete.com.

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