1.1 We (owner and operator of the website is referred to ‘we’ or other forms of it) are committed to safeguarding the privacy of our website visitors.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 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 communications and limit the collection of your personal data. You can access the privacy controls via [URL].
1.5 In this policy, “we”, “us” and “our” refer to Jana Smith, Author. For more information about Jana Smith, please see her About Me page on this website.
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process.[And, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data].
3.2 We may process data enabling us to get in touch with you (“contact data“). [The contact data may include [your name and email address.] The source of the contact data is you.
3.3 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication 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.
3.4 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].
4. Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations – We may process [your personal data] for the purposes of operating our website. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
4.3 Relationships and communications – We may process [contact data, or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email. The legal basis for this processing is namely communications with our website visitors.
4.4 Direct marketing – We may process contact data for the purposes of creating, targeting and sending direct marketing communications by email. The legal basis for this processing is your consent.
4.5 Research and analysis – We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is your consent.
4.6 Legal claims – We may process your personal data 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.
4.7 Legal compliance and vital interests – We may also process 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.
5. Providing your personal data to others
5.1 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.
5.2 Your personal contact data held in our website database will be stored on the servers of our hosting services provider Green Geeks Web Hosting Services. https://www.greengeeks.com/about/
5.5 In addition to the specific disclosures of personal data set out in this Section 5, 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.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under [UK data protection law] OR [EU data protection law] OR [UK and/or EU data protection law].
6.2 We may transfer [your personal data] from the European Economic Area (EEA) to the UK and process that personal data in the UK [for the purposes set out in this policy][, and may permit [our suppliers and subcontractors] to do so,] during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer [your personal data] from the UK to the EEA and process that personal data in the EEA [for the purposes set out in this policy][, and may permit [our suppliers and subcontractors] to do so,] during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6.3 The hosting facilities for our website are situated in Canada. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of Canada. Transfers of data to other countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
6.4 You acknowledge that personal data that you submit through our may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 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.
7.3 We will retain your personal data as follows:
(a) contact data will be retained until you chose to terminate our relationship;
(b) communication data will be retained for a minimum period of one year following the date of the communication in question, and for a maximum period of continued existing communication.
7.4 Notwithstanding the other provisions of this Section 7, 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.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 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 us 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 organization 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.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].
8.4 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.
9. About cookies
9.1 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.
9.2 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.
9.3 Cookies may not 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.
10. Cookies that we use
11. Cookies used by our service providers
12. Managing cookies
12.1 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/enhanced-tracking-protection-firefox-desktop (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://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
13.3 We [may] OR [will] notify you of [changes] OR [significant changes] to this policy [by email].
14. Our details
14.1 This website is owned and operated by Jana Smith.
14.2 Our principal place of business is in Canada.
14.4 You can contact us:
(a) using our website contact form
(c) by email, using firstname.lastname@example.org