Privacy Policy
(Updated for
the General Data Protection Regulation - also known as the GDPR)
1.
Introduction
We are
committed to safeguarding the privacy of our website visitors and service
users; in this policy we explain how we will handle your personal data.
We will ask
you to consent to our use of cookies in accordance with the terms of this
policy when you first visit our website. OR By using our website and
agreeing to this policy, you consent to our use of cookies in accordance
with the terms of this policy.
Our website
incorporates privacy controls which affect how we will process your personal
data. By using the privacy controls, you can specify whether you would like
to receive direct marketing communications and limit the publication of your
information. You can access the privacy controls via the Community User
Settings.
2. How we use
your personal data
In this
Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you,
the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
We may
process data about your use of our website and services ("usage data"). The
usage data may include your IP address, geographical location, browser type
and version, operating system, referral source, length of visit, page views
and website navigation paths, as well as information about the timing,
frequency and pattern of your service use. The source of the usage data is
our analytics tracking system. This usage data may be processed for the
purposes of analysing the use of the website and services. The legal basis
for this processing is consent OR our legitimate interests, namely
monitoring and improving our website and services OR monitoring misuse.
We may
process your account data ("account data"). The account data may include
your name and email address. The source of the account data is you or your
employer. The account data may be processed for the purposes of operating
our website, providing our services, ensuring the security of our website
and services, maintaining back-ups of our databases and communicating with
you. The legal basis for this processing is consent OR our legitimate
interests, namely the proper administration of our website and business OR
the performance of a contract between you and us and/or taking steps, at
your request, to enter into such a contract.
We may
process your information included in your personal profile on our website
("profile data"). The profile data may include your name, address, telephone
and mobile number, email address, profile pictures, and business details.
The profile data may be processed for the purposes of enabling and
monitoring your use of our website and services. The legal basis for this
processing is consent OR our legitimate interests, namely the proper
administration of our website and business OR the performance of a contract
between you and us and/or taking steps, at you request, to enter into such a
contract
We may
process your personal data that are provided in the course of the use of our
services ("service data"). The service data may include resetting your
account details, changing passwords. The source of the service data is you
or your employer. The service data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is consent OR
our legitimate interests, namely the proper administration of our website
and business OR the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract.
We may
process information that you post for publication on our website or through
our services ("publication data"). The publication data may be processed for
the purposes of enabling such publication and administering our website and
services. The legal basis for this processing is consent OR our legitimate
interests, namely the proper administration of our website and business OR
the performance of a contract between you and us and/or taking steps, at
your request, to enter into such a contract.
We may
process information contained in any enquiry you submit to us regarding
products and/or services ("enquiry data"). The enquiry data may be processed
for the purposes of offering, marketing and selling relevant products and/or
services to you. The legal basis for this processing is consent.
We may
process information relating to transactions, including purchases of goods
and services, that you enter into with us and/or through our website
("transaction data"). The transaction data may include your contact details
and the transaction details. The transaction data may be processed for the
purpose of supplying the purchased goods and services and keeping proper
records of those transactions. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract and our legitimate interests, namely
our interest in the proper administration of our website and business.
We may
process information that you provide to us for the purpose of subscribing to
our email notifications and/or newsletters through our service provider
Aptania ("notification data"). The notification data may be processed for
the purposes of sending you the relevant notifications and/or newsletters.
The legal basis for this processing is consent OR the performance of a
contract between you and us and/or taking steps, at your request, to enter
into such a contract.
We may
process information contained in or relating to any communication that you
send to us ("correspondence data"). The correspondence data may include the
communication content and metadata associated with the communication. Our
website will generate the metadata associated with communications made using
the website contact forms. The correspondence data may be processed for the
purposes of communicating with you and record-keeping. The legal basis for
this processing is our legitimate interests, namely the proper
administration of our website and business and communications with users.
We may
process any of your personal data identified in the other provisions of this
policy where necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or out-of-court
procedure. The legal basis for this processing is our legitimate interests,
namely the protection and assertion of our legal rights, your legal rights
and the legal rights of others.
We may
process identify general category of data. This data may include list
specific items of data. The source of this data is identify source. This
data may be processed for specify purposes. The legal basis for this
processing is consent OR our legitimate interests, namely specify legitimate
interests OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
In addition
to the specific purposes for which we may process your personal data set out
in this Section 2, we may also process any of your personal data where such
processing is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital
interests of another natural person.
Please do not
supply any other person's personal data to us, unless we prompt you to do
so.
3. Providing
your personal data to others
Financial
transactions relating to our website and services are OR may be handled by
our payment services provider Paypal. We will share transaction data with
our payment services providers only to the extent necessary for the purposes
of processing your payments, refunding such payments and dealing with
complaints and queries relating to such payments and refunds.
In addition
to the specific disclosures of personal data set out in this Section 3, we
may also disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural
person.
4.
International transfers of your personal data
In this
Section 4, we provide information about the circumstances in which your
personal data may be transferred to countries outside the European Economic
Area (EEA).
The hosting
facilities for our website are situated in United Kingdom. The European
Commission has made an "adequacy decision" with respect to the data
protection laws of each of these countries. Transfers to each of these
countries will be protected by appropriate safeguards, namely the use of
standard data protection clauses adopted or approved by the European
Commission OR specify appropriate safeguards.
You
acknowledge that personal data that you submit for publication through our
website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.
5. Retaining
and deleting personal data
This Section
5 sets out our data retention policies and procedure, which are designed to
help ensure that we comply with our legal obligations in relation to the
retention and deletion of personal data.
Personal data
that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
We will retain and delete your personal data as follows: personal data
category will be retained for period of one year following start date of
membership or membership renewal, at the end of which period it will be
deleted from our systems.
Notwithstanding the other provisions of this Section 5, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.
6. Amendments
We may update
this policy from time to time by publishing a new version on our website.
You should
check this page occasionally to ensure you are happy with any changes to
this policy.
We may notify
you of changes to this policy by email or through the private messaging
system on our website.
7. Your
rights
You may
instruct us to provide you with any personal information we hold about you;
provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose,
we will usually accept a photocopy of your passport certified by a solicitor
or bank plus an original copy of a utility bill showing your current
address).
We may
withhold personal information that you request to the extent permitted by
law.
You may
instruct us at any time not to process your personal information for
marketing purposes.
In
practice, you will usually either expressly agree in advance to our use of
your personal information for marketing purposes, or we will provide you
with an opportunity to opt out of the use of your personal information for
marketing purposes.
8. About cookies
A cookie is a
file containing an identifier (a string of letters and numbers) that is sent
by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
Cookies may
be either "persistent" cookies or "session" cookies: a persistent cookie
will be stored by a web browser and will remain valid until its set expiry
date, unless deleted by the user before the expiry date; a session cookie,
on the other hand, will expire at the end of the user session, when the web
browser is closed.
Cookies do
not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the
information stored in and obtained from cookies.
9. Cookies
that we use
We use
cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our
website and as you navigate our website (cookies used for this purpose are:
identify cookies);
(b) status - we use cookies to help us to determine if you are logged into
our website (cookies used for this purpose are: identify cookies);
(c) personalisation - we use cookies to store information about your
preferences and to personalise the website for you (cookies used for this
purpose are: identify cookies);
(d) security - we use cookies as an element of the security measures used to
protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally (cookies used
for this purpose are: identify cookies);
(e) analysis - we use cookies to help us to analyse the use and performance
of our website and services (cookies used for this purpose are: identify
cookies); and
(t) cookie consent - we use cookies to store your preferences in relation to
the use of cookies more generally (cookies used for this purpose are:
identify cookies).
10. Managing cookies
Most
browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to
version. You can however obtain up-to-date information about blocking and
deleting cookies via these links:
(a)
https://support.google.com/chrome/answer/95647?hl=en
(Chrome);
(b)
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c)
http://www.opera.com/help/tutorials/security/cookies/
(Opera);
(d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e)
https://support.apple.com/kb/PH21411 (Safari); and
(f)
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
Blocking all
cookies will have a negative impact upon the usability of many websites.
If you block
cookies, you will not be able to use all the features on our website.
11. Our
details
This website
is owned and operated by Mckenzie Publishing Limited. We are registered in
England and Wales under registration number
3076505,
and our registered office is at
1 Tudor
Business Centre Station Yard, Waterhouse Lane, Kingswood, Tadworth, England,
KT20 6EN.
Our principal
place of business is at 7 Acacia Court, Sheendale Road, Richmond upon
Thames, TW9 2JP.
You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time
to time; or
(d) by email, using the email address published on our website from time to
time.
14. Data
protection officer:
Adrian Davies
– telephone 07956 322 810.
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