1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Account: means an account required to access and/or use certain areas and features of Our Site.
Cookie: means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of our Site. Details of the Cookies used by Our Site are set out in Part 14, below.
Cookie Law: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About Us
Our Site is owned and operated by Mark Bowden Ltd, a limited company, partnership, registered in England under company number 07880673.
Registered address: 46 Temeraire Road, Plymouth, PL5 3UB
VAT number: 226640027
Data Protection Officer: Mark Bowden
Email address: email@example.com
Telephone number: 07575203332
Postal Address: 46 Temeraire Road, Plymouth, PL5 3UB
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?
We collect certain information that you voluntarily provide when you create an account with us. This information may include personally identifiable information such as your name and email address as well as a password that you create. You may access and make changes to your stored account information at any time by logging into your account and clicking on the “My Account” link. When you purchase one of our products or services, we ask for additional personally identifiable information such as your credit card information and billing address solely for the purpose of processing your payment and fulfilling your order.
We may use certain standard web measurement and tracking technologies, such as “cookies,” web server logs, or other statistics programs to collect information about you, your online behavior, and/or your computer or other device from which you access our web site. This information may include your preferences and settings, IP address, browser type, web pages visited, date and time of those visits, content viewed, the website you arrived from, and other clickstream data. If you do not want this type of information to be collected, your computer or other device may allow you to block the use of these technologies. (Doing so make affect the functionality of our site.) In addition, we may utilize use web beacons (also known as “action tags” or “one pixel .gif files”), provided by our advertising serving partner, to measure the effectiveness of, and otherwise manage, our online advertising. These web beacons enable our advertising server to recognize you when you visit our web site and to determine which banner ads bring users to our website. We do not use spyware, adware or any other similarly intrusive software.
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data:
• Date of birth
• Email address
• Telephone number
• Business name
• Job title
• Payment information
• Information about your preferences and interests
• IP address
• Web browser type and version
• Operating system
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
• Providing and managing your Account
• Providing and managing your access to Our Site
• Personalising and tailoring your experience on Our Site
• Supplying our products OR services to you. Your personal details are required in order for us to enter into a contract with you
• Personalising and tailoring our products OR services for you
• Communicating with you; This may include responding to emails or calls from you
• Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by requesting via email to firstname.lastname@example.org
• Analysing your use of Our site and gathering feedback to enable us to continually improve Our site and your user experience
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
The information we collect from you will be used to provide and improve the products and services offered through our website. We also use certain information that we collect for research regarding our customers’ online behavior. We may also use your information to contact you regarding new features, services, promotions, or user surveys or to respond to your comments or questions.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
• If you have created an account your details will be kept until you request that they are deleted. This will enable the products that you have purchased to remain accessible to you. You may request this to be deleted, see section 15 on how to do this.
• If you request to be part of the email mailing list your details will be kept until you request they are deleted. If you unsubscribe, this will prevent you from receiving any further correspondence from us. However, this will not delete your details as we keep these on records to prevent them from being re-added to the email recipients list. You can request for your details to be deleted. See section 15 on how to do this.
9. How and Where Do You Store or Transfer My Personal Data?
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission.
10. Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply certain products or services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
1. In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails OR at the point of providing your details and by managing your Account).
2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ for example, if you make repetitive requests a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 4 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for:
1. Tracking how visitors use our site (e.g. Google Analytics, BetterMetrics) to help us improve the service.
2. Providing additional services, such as our email subscription forms (e.g. ConvertKit) or on-site chat (Olark).
3. Providing additional content that enhances our website, e.g YouTube and Vimeo videos.
For more details, please refer to the table below. Third-party Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|cookie_notice_accepted||Indicate if cookie notice has been accepted||Yes|
And the following third-party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|fr||Facebook Inc.||Facebook custom audience|
|__cfduid||CloudFlare||Allows CloudFlare to apply security settings on a per-client basis. Read More...|
|XSRF-TOKEN||ConvertKit LLC||Token that allows our email signup forms to work|
|_mailapp_session||ConvertKit LLC||Used by email signup forms|
|__stripe_mid||Stripe||Randomly generated session for recognising a client|
|__stripe_sid||Stripe||Randomly generated session for recognising a client|
|_gat_gtag_U _gat_gtag_[property_id]||Google Analytics Which Google Analytics property should track metrics|
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our site use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics services used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|PHPSESSID||Third||Used to distinguish users||BetterMetrics|
|_ga||Third||Used for analytics and service improvement||Google Inc.|
|_gid||Third||Used for analytics and service improvement||Google Inc.|
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Mark Bowden:
Email address: email@example.com
Telephone number: 07575 203332
Postal Address: 46 Temeraire Road, Plymouth PL5 3UB
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.