Privacy Policy

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally Identifiable Information' (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

 

What personal information do we collect from the people that visit our blog, website or app?

 

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.

 

When do we collect information?

 

We collect information from you when you register on our site, subscribe to a newsletter or enter information on our site.

 

How do we use your information?

 

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
 

      • To send periodic emails regarding your order or other products and services.

 

How do we protect your information?

 

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
 

We use regular Malware Scanning.
 

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

 

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.

 

All transactions are processed through a gateway provider and are not stored or processed on our servers.

 

Do we use 'cookies'?

 

We do not use cookies for tracking purposes

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.

 

If you turn cookies off .

 

Third-party disclosure

 

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.

 

Third-party links

 

We do not include or offer third-party products or services on our website.

 

Google

 

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en 
 

We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

      • Demographics and Interests Reporting

 

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

 

California Online Privacy Protection Act

 

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

      • On our Privacy Policy Page

Can change your personal information:

      • By emailing us

How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It's also important to note that we do not allow third-party behavioral tracking

 

COPPA (Children Online Privacy Protection Act)

 

When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
 

We do not specifically market to children under the age of 13 years old.

Do we let third-parties, including ad networks or plug-ins collect PII from children under 13?

 

Fair Information Practices

 

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
 

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify you via email

      • Within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

 

GDPR Compliance Statement

 

 

Introduction

The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.

 

The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

 

Our Commitment

I am committed to ensuring the security and protection of the personal information that I process, and to provide a compliant and consistent approach to data protection. I have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, I recognize my obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill/any relevant country DP law.

 

I am dedicated to safeguarding the personal information under my remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. My preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

 

How We are Preparing for the GDPR

This site is protected by SSL certificate and Mailerlite is used for newsletters and is also protected. No information, other than names and emails given if you opt-in for a newsletter or discussion board or cookies for site tracking and site improvement, will be saved in any way.

 

S.E. Rose already has a consistent level of data protection and security across her website and newsletter, however it is her aim to be fully compliant with the GDPR by 25th May 2018. Preparation for these changes included:

• Information Audit - carrying out a system-wide information audit to identify and assess what personal information I hold, where it comes from, how and why it is processed and if and to whom it is disclosed.

• Policies & Procedures - revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -

  • Data Protection – my main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that I understand and adequately disseminate and evidence my obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.

  • Data Retention & Erasure – I have updated my retention policy and schedule to ensure that I meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. I have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.

  • Data Breaches – My breach procedures ensure that I have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. My procedures are robust.

  • International Data Transfers & Third-Party Disclosures – where S.E. Rose stores or transfers personal information outside the EU, I have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. My procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. I carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.

  • Subject Access Request (SAR) –I have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. My new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.

• Legal Basis for Processing – I am reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, I also maintain records of my processing activities, ensuring that my obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.

• Privacy Notice/Policy – we [have revised/are revising] My Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information I process have been informed of why I need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.

• Obtaining Consent - I have revised my consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how I use it and giving clear, defined ways to consent to me processing their information. I have developed stringent processes for recording consent, making sure that I can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.

• Direct Marketing - I have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.

• Data Protection Impact Assessments (DPIA) – I do not process information that is high risk.

• Processor Agreements – where I use any third-party to process personal information on our behalf (Mailerlite), Mailerlite has stringent processes and due diligence procedures for ensuring that they (as well as me), meet and understand their/my GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.

• Special Categories Data - I do NOT obtain and process any special category information.

 

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, I provide easy to access information via my website of an individual’s right to access any personal information that S.E. Rose author processes about them and to request information about: -

• What personal data I hold about them

• The purposes of the processing

• The categories of personal data concerned

• The recipients to whom the personal data has/will be disclosed

• How long I intend to store your personal data for

• If I did not collect the data directly from them, information about the source

• The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this

• The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from me and to be informed about any automated decision-making that I use

• The right to lodge a complaint or seek judicial remedy and who to contact in such instances

 

Information Security & Technical and Organisational Measures

I takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that I process. I have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: -

 

SSL Certification

Mailerlite Privacy: https://www.mailerlite.com/privacy-policy

Wix Privacy: https://www.wix.com/about/privacy

 

GDPR Roles and Employees

S.E. Rose has designated is self-designated as the data privacy person for complying with the new data protection Regulation. I am assessing my GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

 

S.E. Rose understands that awareness and understanding is vital to the continued compliance of the GDPR.

 

 

If you have any questions about my preparation for the GDPR, please contact S.E. Rose at seroseauthor@gmail.com