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PRIVACY POLICY

Type of websites: Ecommerce and blogs
Effective date: 28th March 2024

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www.malcolmdown.co.uk and www.sarahgracepublishing.co.uk (the "Sites") are owned and operated by Malcolm Down. Malcolm Down is the data controller and can be contacted at:

malcolm@malcolmdown.co.uk

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Purpose
The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Sites of the following:

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  1. The personal data we will collect;

  2. Use of collected data;

  3. Who has access to the data collected;

  4. The rights of Sites users; and

  5. The Sites's cookie policy.

 

This Privacy Policy applies in addition to the terms and conditions of our Sites.

 

GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

 

Consent
By using our Sites users agree that they consent to:

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  1. The conditions set out in this Privacy Policy.

 

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

 

You can withdraw your consent by: Unsubscribing or contacting Malcolm on malcolm@malcolmdown.co.uk

 

Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal bases to collect and process the personal data of users in the EU:

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  1. Users have provided their consent to the processing of their data for one or more specific purposes; and

  2. Processing of user personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by the interests or fundamental rights and freedoms of users. Our legitimate interest(s) are: Finding out about our products and buying our products.

 

Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

 

Data Collected Automatically
When you visit and use our Sites, we may automatically collect and store the following information:

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  1. IP address;

  2. Location;

  3. Hardware and software details;

  4. Clicked links; and

  5. Content viewed.

 

Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Sites:

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  1. First and last name;

  2. Email address;

  3. Phone number;

  4. Address; and

  5. Payment information.

 

This data may be collected using the following methods:

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  1. Purchase process; and

  2. Newsletter sign up.

 

How We Use Personal Data
Data collected on our Sites will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Sites. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for the following purposes:

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  1. Statistics and marketing.

 

The data we collect when the user performs certain functions may be used for the following purposes:

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  1. Communication; and

  2. Delivery of products.

 

Who We Share Personal Data With
 

Employees
We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

 

Third Parties
We may share user data with the following third parties:

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  1. Google analytics;

  2. Social media platforms; and

  3. Email marketing provider (We a combination of Mailchimp and Wix.com for all our marketing communications. Read their respective privacy policies here - https://mailchimp.com/legal/ and  https://www.wix.com/about/privacy)

 

We may share the following user data with third parties:

  1. Action data e.g. links clicked while using sites; and

  2. Email addresses.

 

We may share user data with third parties for the following purposes:

  1. Targeted advertising; and

  2. Communication.

 

Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.

 

Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:

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  1. If the law requires it;

  2. If it is required for any legal proceeding;

  3. To prove or protect our legal rights; and

  4. To buyers or potential buyers of this company in the event that we seek to sell the company.

 

If you follow hyperlinks from our Sites to another Sites, please note that we are not responsible for and have no control over their privacy policies and practices.

 

How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

 

How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities, namely in the third-party providers, Mailchimp and Wix.com. (Read their respective privacy policies here - https://mailchimp.com/legal/ and  https://www.wix.com/about/privacy). All data is only accessible to our employees.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

 

Your Rights as a User
Under the GDPR, you have the following rights:

  1. Right to be informed;

  2. Right of access;

  3. Right to rectification;

  4. Right to erasure;

  5. Right to restrict processing;

  6. Right to data portability; and

  7. Right to object.

 

Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.

 

How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact Malcolm on malcolm@malcolmdown.co.uk
 

How to Opt-Out of Data Collection, Use or Disclosure
In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:

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  1. You can opt-out of the use of your personal data for marketing emails. You can opt-out by clicking "unsubscribe" on the bottom of any marketing email.

 

Cookie Policy
A cookie is a small file, stored on a user's hard drive by a websites. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

 

We use the following types of cookies on our Sites:

  1. Functional cookies
    Functional cookies are used to remember the selections you make on our Sites so that your selections are saved for your next visits;

  2. Analytical cookies
    Analytical cookies allow us to improve the design and functionality of our Sites by collecting data on how you access our Sites, for example data on the content you access, how long you stay on our Sites, etc;

  3. Targeting cookies
    Targeting cookies collect data on how you use the Sites and your preferences. This allows us to personalise the information you see on our Sites for you; and

  4. Third-Party Cookies
    Third-party cookies are created by a websites other than ours. We may use third-party cookies to achieve the following purposes:    ​ 

a. Monitor user behaviour to tailor marketing to their interests.

 

Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

 

Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner's Office in the UK.

 

Contact Information
If you have any questions, concerns or complaints, you can contact Malcolm at malcolm@malcolmdown.co.uk

 

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