privacy and cookies policy

1. Introduction

 

1.1 We are committed to safeguarding the privacy of our website visitors and the users of any services supplied through this website such as the writer’s newsletter.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, "we", "us" and "our" refer to the author Katherine Davies and her office.

 

2. How we use your personal data

 

2.1 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.

2.2 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.

2.3 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.

2.4 We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of providing you information or offering or marketing relevant services to you. The legal basis for this processing is consent.

2.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("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.

2.6 We may process any of your personal data identified in 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.

2.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.8 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.

2.9 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

 

3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2 Our website is managed and hosted by Wix and partners, and your personal data and this website is stored on the servers of the Wix hosting services providers. We therefore may disclose personal data to Wix and their partners and other suppliers and contractors insofar as reasonably necessary for the security, administration, analysis of site usage, good functioning and effective provision and performance of this website and its services.

3.3 In addition to the specific disclosures of personal data set out in this Section 3, we may 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

4. International transfers of your personal data

 

4.1 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).

4.2 Wix.com Ltd is based in Israel, and may store and process Personal Information in the USA, Europe, Israel, or other jurisdictions, whether by ourselves or with the help of our affiliates and service providers.ֿ Suppliers and subcontractors connected to Wix and other suppliers and contractors supplying services related to this website may be located outside the EEA. Wix’s data storage providers are contractually committed to protect and secure your data. Among other frameworks, Wix adheres to the EU – US & to the Swiss-US Privacy Shield Principles, for further protecting and enhancing our users’ privacy.

4.3 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

 

5.1 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.

5.2 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.

5.3 We will retain your personal data as follows:

(a) usage data will be retained for a minimum period of 5 years following the date of collection, and for a maximum period of 10 years following that date;

(b) publication data will be retained for a minimum period of 3 years following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period of 5 years following that date;

(c) Enquiry data will be retained for a minimum period of 3 years following the date of the enquiry, and for a maximum period of 5 years following that date;

(d) Notification data will be retained for a minimum period of 1 year following the date that we are instructed to cease sending the notifications, and for a maximum period of 2 years following that date providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications; and

5.4 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. Your rights

 

6.1 In this Section 6, we have listed the rights that you have under data protection law.

6.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure - you can ask us to erase your personal data;

(d) the right to restrict processing - you can ask use to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

6.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

6.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].

 

7. About cookies

 

7.1 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.

7.2 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.

7.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

 

8. Cookies that we use

 

8.1 We use cookies for the following purposes:

(a) authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;

(b) 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;

(c) analysis - we use cookies to help us to analyse the use and performance of our website and services; and

(d) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

 

9. Cookies used by our service providers

 

9.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/and you can review Google's privacy policy at https://policies.google.com/privacy

9.3 We use Wix and their partners for the hosting and management of this website including the storing of personal data. This service uses cookies. You can view the privacy policy of this service provider at https://www.wix.com/about/privacy

 

10. Managing cookies

 

10.1 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(Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac(Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy(Edge).

10.2 Blocking all cookies will have a negative impact upon the usability of many websites.

10.3 If you block cookies, you will not be able to use all the features on our website.

 

11. Amendments

 

11.1 We may update this policy from time to time by publishing a new version on our website.

11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

 

12. Our details

 

12.1 This website is owned and operated by Katherine Davies

12.2 Our principal place of business is in Lombardia, Italy

12.3 You can contact us by emailing k at davieswriter.com

 

13. Data protection officer

 

13.1 Our data protection officer is Katherine Davies, email k at davieswriter.com for any queries 

 

Our thanks to SEQ Legal for the EU compliant template upon which this policy is based.

Copyright © 2020 Katherine Davies - All Rights Reserved.

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