Privacy Policy.

1. Who we are

This Privacy Policy explains how Caroline Girvan Ltd collects, uses and protects personal data when you use carolinegirvan.com.

Caroline Girvan Ltd is a company registered in Northern Ireland under company number NI673783. In this Privacy Policy, “we”, “us” and “our” means Caroline Girvan Ltd.

For privacy enquiries, including requests about your personal data, you can contact us at:

Email: legal@carolinegirvan.com

Carolinegirvan.com is Caroline Girvan’s personal brand website. It is not the CGX subscription platform. Paid subscriptions, member accounts, payments and access to CGX are handled separately through cgxapp.com, which is operated by CGX Ltd and governed by its own legal terms and privacy documents.

2. What personal data we collect

We aim to keep personal data collection on this website limited and proportionate.

If you contact us through the website contact form, we may collect your name, email address, message content and any enquiry type or routing category you select. We may also process technical information needed to deliver, protect and manage the form, such as basic submission metadata or anti-spam information.

If you subscribe to our newsletter, we may collect your email address and information needed to manage your subscription, including your consent status, unsubscribe status and delivery information.

We also use Plausible Analytics to understand website usage in an aggregate, privacy-respecting way. Plausible is intended to operate without cookies and without tracking individual visitors across websites.

3. How we use your personal data

We may use your personal data to:

• respond to enquiries submitted through the website
• route enquiries to the correct team or platform, including CGX-related support enquiries where appropriate
• send newsletters where you have subscribed
• manage unsubscribe and suppression records
• understand aggregate website usage and improve the website
• protect the website from misuse, spam or technical issues
• comply with legal obligations

We do not use this website for behavioural advertising, retargeting, affiliate tracking or profiling.

4. Lawful bases for processing

We rely on the following lawful bases under UK data protection law:

• Consent, where you subscribe to a newsletter or otherwise give consent for a specific use.
• Legitimate interests, where we respond to enquiries, manage website operations, understand aggregate site performance, protect the website from misuse and route relevant enquiries appropriately.
• Legal obligation, where we need to keep or disclose information to comply with applicable law.

Where we rely on legitimate interests, we only do so where we consider that our interests are not overridden by your rights and freedoms.

5. Newsletter

You can subscribe to our newsletter by providing your email address. We use your email address to send the newsletter and manage your subscription. You can unsubscribe at any time using the unsubscribe link in the newsletter or by contacting us.

We may use Beehiiv or another email service provider to send and manage the newsletter on our behalf. That provider acts as a processor where it handles personal data for us.

If you unsubscribe, we may retain a suppression record of your email address to ensure that your unsubscribe preference is respected and that your email address is not accidentally reintroduced to the mailing list later.

6. Contact enquiries

If you contact us through the website, we use the information you provide to review and respond to your enquiry. If your enquiry relates to CGX membership, billing, account access or support, we may redirect you to the appropriate CGX support route or forward the enquiry to the relevant team where this is necessary to handle your request.

Carolinegirvan.com is not the CGX member-support platform. CGX subscriptions and member support are handled separately by CGX Ltd.

7. Analytics

We use Plausible Analytics to understand how visitors use the website and how the website performs. Plausible is designed to provide aggregate analytics without using cookies and without creating individual visitor profiles.

The analytics information we receive is used to review general website performance, understand which pages are being visited, identify technical issues and improve the website experience. We do not use Plausible for behavioural advertising, retargeting, cross-site tracking or individual profiling.

8. Sharing personal data

We may share personal data with service providers who help us operate the website, send newsletters, process contact form submissions, manage hosting, security, analytics or technical infrastructure.

These providers may include:

• Plausible Analytics
• Beehiiv
• website hosting and infrastructure providers
• form, email routing or anti-spam providers
• professional advisers, where necessary

We do not sell personal data.

If personal data is transferred outside the United Kingdom, we will take steps designed to ensure that appropriate safeguards are in place, such as adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement or other lawful transfer mechanisms.

9. Retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

As a guide:

• newsletter subscriber data is kept while you remain subscribed
• unsubscribe or suppression records may be kept for as long as necessary to honour your unsubscribe preference
• contact enquiries are normally kept only for as long as needed to handle the enquiry and maintain a reasonable business record
• analytics data is retained in aggregate form for website performance and reporting purposes

We may keep information for longer where needed for legal, regulatory, security or dispute-resolution purposes.

10. Your rights

You may have the right to:

• access your personal data
• ask us to correct inaccurate personal data
• ask us to erase personal data
• object to processing based on legitimate interests
• restrict processing
• receive certain personal data in a portable format
• withdraw consent where processing is based on consent

To exercise these rights, contact us at legal@carolinegirvan.com.

You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection matters. You can find more information on the ICO website.

11. Children

This website is not directed at children. We do not knowingly collect personal data from children through this website. If you believe a child has provided personal data to us, contact us at legal@carolinegirvan.com.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The current version will be published on this page with its effective date.