1. Introduction
1.1 I am committed to safeguarding the privacy of visitors to my site and readers of my books.
1.2 This policy applies where I am acting as a data controller with respect to the personal data of my readers and visitors to my site; in other words, where I determine the purposes and means of the processing of that personal data.
1.3 The host of my website is WordPress. WordPress may gather information about you if you visit this site. The information WordPress gathers may be found here. I will only gather personal data about you if you sign up to my author newsletter.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).
3. How I use your personal data
3.1 In this Section 3 I have set out:
(a) the general categories of personal data that I may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 I may process your email address, name (if you supply it), and referral source (“usage data“). The legal basis for this processing is your consent in signing up to my newsletter.
3.3 I 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 my legitimate interest, namely the protection and assertion of my legal rights, your legal rights and the legal rights of others.
3.4 I 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 my legitimate interest, namely the proper protection of my business against risks.
3.5 In addition to the specific purposes for which I may process your personal data set out in this Section 3, I may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 I may disclose your personal data to third parties insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, the establishment, exercise or defence of legal claims, whether in court proceedings, in an administrative or out-of-court procedure, or where such disclosure is necessary to protect your vital interests or the vital interests of another natural person.
4.2 Where your personal data is held by WordPress, it will be stored on Word Press’s servers. Where your personal data is collected for the purposes of my newsletter, it will be held on MailChimp’s servers.
5. International transfers of your personal data
5.1 In this Section 5, I provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for my website and newsletter mailing list are situated primarily in the United States. WordPress and MailChimp both certify to the Privacy Shield standard which guarantees that data transfers will be protected by appropriate safeguards.
5.3 You acknowledge that personal data that you submit through my website or mailing list may be available, via the internet, around the world. I cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out my data retention policies and procedure, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 I will retain your personal data for a maximum of seven (7) years beyond the closure of my mailing list.
6.4 Notwithstanding the other provisions of this Section 6, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Your rights
7.1 In this Section 7, I have listed the rights that you have under data protection law.
7.2 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 me to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask me to erase your personal data;
(d) the right to restrict processing – you can ask me 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 I transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about my processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of my processing of your personal data is consent, you can withdraw that consent.
7.3 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/.
7.4 You may exercise any of your rights in relation to your personal data by written notice to me with respect of my mailing list at emmafrostuk@gmail.com.
8. About cookies
8.1 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.
8.2 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.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal data that I store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that I use
9.1 I do not use cookies.
10. Cookies used by my service providers
10.1 My service providers use cookies and those cookies may be stored on your computer when you visit this site.
10.2 My service provider uses Google Analytics. Google Analytics gathers information about the use of my website by means of cookies. The information gathered is used to create reports about the use of my 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.
11. Managing cookies
11.1 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).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will probably not be able to use all the features on my website.
12. Amendments
12.1 I may update this policy from time to time by publishing a new version on my website.
12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
13. My details
13.1 This website is owned and operated by E J Frost.
13.2 You can contact me by email at emmafrostuk@gmail.com.
13.3. I am the data protection officer.
E J Frost 