1. Who I Am
I am Shirley Cooper, a UK-based sole trader operating a creative, educational and digital business.
My business activities include The Celtic Alchemist, The Torc, Flight Calm, digital publications, colouring books, downloadable resources, audio products, online memberships and other related products and services.
This Privacy Policy explains how I collect, use, store and protect personal information when you interact with my business.
It applies to my websites, sales pages, forms, products, memberships and communications that link to this policy, including:
Other websites and online services operated by Shirley Cooper that refer to this policy
I am the data controller responsible for the personal information described here.
Email: shirley@shirleycooper.com
Business address: 12, Paynes Pitch, Churchdown, Gloucestershire, GL3 2NP
2. What Personal Information I Collect
Depending on how you interact with my business, I may collect:
Your name and email address
Contact and billing details
Information provided through contact forms, waiting lists and registrations
Details of products or services purchased
Payment and transaction records, excluding full payment card details
Membership account and subscription information
Email preferences and marketing consent records
Enquiries, messages and customer support correspondence
Information you voluntarily share within online communities
Technical information such as IP addresses, browser details and website usage data where collected by my service providers
I aim to collect only the information reasonably necessary for the relevant purpose.
3. How I Use Your Information
I use personal information to:
Process orders and deliver purchased products or services
Provide access to digital downloads, audio products, publications and membership resources
Manage customer accounts and subscriptions
Respond to enquiries and provide customer support
Manage waiting lists and provide requested launch updates
Send newsletters and promotional emails where permitted
Administer online communities and verify membership eligibility
Maintain the security and operation of my websites
Keep appropriate business, financial and accounting records
Comply with applicable legal obligations
I do not sell or rent your personal information to third parties for their own marketing purposes.
4. Legal Bases for Processing
Under UK GDPR, I rely on the following lawful bases where appropriate:
Contract: To fulfil purchases, provide memberships and deliver products or services under an agreement with you.
Consent: For marketing communications where consent is required, and for other activities that legally require your permission.
Legitimate interests: For reasonable business activities such as responding to enquiries, maintaining website security and administering services, where these interests do not override your rights.
Legal obligation: To comply with applicable tax, accounting and other legal requirements.
Where I rely on consent, you can withdraw it at any time.
5. Email Communications and Marketing
You may receive emails from my business when you purchase a product, join a waiting list, request a free resource or choose to subscribe to updates.
Service-related emails may include order confirmations, access information, subscription notifications and support communications.
Marketing emails may include newsletters, creative inspiration, business updates, new products, publications, membership opportunities and special offers.
I send marketing communications where I have the appropriate permission or another lawful basis under applicable electronic marketing rules.
You can unsubscribe from marketing emails using the unsubscribe link provided or by emailing me directly.
Unsubscribing from marketing will not normally affect access to products you have purchased or prevent essential service communications.
6. Waiting Lists and Free Resources
When you join a waiting list or request a free resource, I use the information you provide to fulfil that request.
For example, joining The Torc waiting list allows me to communicate with you about the membership and its launch.
Where I offer an additional marketing subscription, your preferences will be handled according to the choices presented when you register.
You may ask to be removed from a waiting list or unsubscribe from marketing communications at any time.
7. Purchases and Payment Processing
Payments for my products, memberships and services may be processed securely through PayPal or Stripe, depending on the options available at checkout.
These payment providers process information according to their own privacy policies.
I do not store customers' full payment card details.
I may receive transaction information such as purchase amounts, payment status, billing details and transaction references for order fulfilment, support, accounting and legal purposes.
8. Memberships and Online Communities
Some of my services include online memberships, educational materials, creative activities and community participation.
Membership accounts, resources and digital content may be delivered through Systeme.io or another platform identified when you register.
Certain community activities, including The Torc's private Hearth community, take place through Facebook.
If you participate in a Facebook group, Meta's privacy practices and the group's privacy settings also apply.
Your Facebook profile details, posts, comments and interactions may be visible to other members of the group.
I may process limited information to confirm membership eligibility, manage access and moderate community activities.
Please respect the privacy of other participants and avoid sharing their personal information without permission.
9. Third-Party Service Providers
I use external service providers to help operate my business.
These include, where relevant:
Systeme.io: Website hosting, sales funnels, customer records, email communications, digital product delivery and membership management
Stripe: Payment processing
PayPal: Payment processing
Meta/Facebook: Social media and community participation
Domain, hosting and other technical service providers required for business operations
Some providers process information on my behalf, while others act as independent data controllers for their own services.
I share personal information only where reasonably necessary for the relevant service, or where required by law.
10. International Data Transfers
Some of the service providers I use may process or store personal information outside the United Kingdom.
Where UK data protection law requires safeguards for international transfers, appropriate arrangements must be in place. These may include UK adequacy regulations or approved contractual safeguards.
You can contact me for further information about relevant international data transfers.
11. How Long I Keep Your Information
I retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including applicable legal, accounting and reporting obligations.
Retention periods depend on the information involved.
For example:
Waiting list information is kept while needed for the relevant waiting list or launch, unless another lawful reason for retention applies.
Marketing subscription information is kept while you remain subscribed, with limited records potentially retained to respect opt-out requests.
Customer and membership information is kept as necessary to provide services, administer accounts and manage appropriate business records.
Financial records are retained for the periods required by applicable tax and accounting law.
Customer correspondence is retained where reasonably necessary for support, administration or dispute resolution.
You can request deletion of your personal information, subject to applicable legal exceptions.
12. Cookies and Website Technologies
My websites are operated using Systeme.io and may use cookies or similar technologies to support website functionality, security, visitor statistics and other platform services.
I have not independently installed Google Analytics, Meta Pixel or separate advertising-tracking tools on the websites covered by this policy.
A cookie named v has been observed on The Torc website. Its precise purpose, duration and whether it can be disabled are currently being clarified with Systeme.io.
Where cookies or similar technologies require consent under UK law, they must not be used before the required consent is obtained.
Where an applicable legal exception allows their use without prior consent, any associated transparency and objection requirements must still be met.
You can also manage or delete cookies using your browser settings.
This section will be updated as further information about the platform's cookies becomes available.
13. Information Security
I take reasonable technical and organisational steps to protect personal information against unauthorised access, loss, misuse and disclosure.
These include using established service providers and appropriate account security measures.
No internet-based system can be guaranteed completely secure.
14. Your Data Protection Rights
Under UK data protection law, you may have the right to:
Request access to personal information held about you
Request correction of inaccurate information
Request deletion of information in certain circumstances
Request restriction of processing
Object to certain processing activities, including direct marketing
Request data portability where applicable
Withdraw consent where processing relies on consent
Raise concerns about how your information is handled
These rights are subject to applicable legal conditions and exceptions.
To exercise your rights, please email:
I will respond within the timescales required by UK data protection law, normally within one calendar month.
You also have the right to complain to the Information Commissioner's Office (ICO):
15. Children and Young People
My websites, memberships and digital services are generally intended for adults unless a particular product or service clearly states otherwise.
Some publications or creative resources may be suitable for children or families.
I do not knowingly collect children's personal information through services intended exclusively for adults.
If you believe a child has provided personal information inappropriately, please contact me.
16. External Links
My websites and communications may contain links to third-party websites, social media platforms or external services.
These organisations operate their own privacy policies and data protection practices.
I encourage you to review their privacy information before submitting personal details.
17. Changes to This Privacy Policy
I may update this policy when my business activities, technology providers, data practices or legal obligations change.
The latest version will be published at:
https://shirleycooper.com/privacy-policy
The date at the top of the policy will indicate when it was last updated.
18. Contact
Shirley Cooper
Sole Trader
The Cotswolds, Gloucestershire, United Kingdom
Business address: 12, Paynes Pitch, Churchdown, Gloucestershire, GL3 2NP
Email: shirley@shirleycooper.com
Website: https://shirleycooper.com