Privacy Notice

3. GDPR PRINCIPLES

This chapter covers some basic things about the GDPR that you should know and that we need to adhere to.

3.1. Scope

The GDPR covers the protection of EU citizens regardless of where this data is stored or processed,  Even a website on the other side of the planet, if it is intending to process data for EU citizens, must conform to the GDPR regulations.

3.2. Principles

In protecting EU citizens data the GDPR looks to the following principles regarding your data :-

“Data is specified, explicit and legitimate”.  When we ask you for your data we are required to tell you what it is for in terms that specify exactly what it is we need, why we need it and that when we explain this it is written out in clear and understandable terms.

The 5 main principles the GDPR adds are as follows:

• Data Minimisation
• Accuracy
• Storage Limitation
• Integrity and Confidentiality
• Accountability.

3.3. Lawfulness of Processing

This article essentially lays out that we have to ask you for your consent to process your data, that the processes we’re going to put that data through is relevant to our activity of providing the services we have for you and that there’s a real need for the data collection in order for us to proceed.

3.4. Conditions for Consent 

This is one of the more important articles that you should be aware of.  There are 3 main parts to it as follows :-

• We are required to … “demonstrate that the data subject has consented to processing of his or her personal data”. You have to actively agree to us processing your data
• Any form we present to you requires to be … “clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language”.
• This is the important one you should know about.  You … “will have the right to withdraw his or her consent at any time. It will be as easy to withdraw as to give consent”. This should make all of that a whole lot easier to do

3.5. Conditions Applicable to Child’s Consent

There are very specific GDPR rules governing data capture for children.  We’re not going to ask for any children data. As such this means that only adults, who can give their data willingly, will be allowed access to our site.  The GDPR lays out that a child is “below the age of 16 years”. So you must be 16 years old or over to access our site.

3.6. Processing Special Categories

The “Special Categories” cover data which reveals any of the following :-

• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• genetic or biometric data concerning health
• details of sex life or sexual orientation

We won’t be asking you for any of the above anyway

4. GDPR RIGHTS OF THE DATA SUBJECT

This chapter covers your rights under the GDPR.  We’ll highlight the bits that we are required to and bits we think you should know

4.1. Transparent Information, Communication and Modalities

The GDPR allows you to request information about your data from us.  It lays out regulations on what we are required to do when fulfilling this.  Where you ask us we are required to provide :-

• data “in a concise, transparent, intelligible and easily accessible form, using clear and plain language” 
• data “orally” where we’ve previously identified you
• information on “any action taken on a request”.  We need to keep you informed
• the information “free of charge”.  It’s free unless your request is deemed to be excessive

So you can ask us what you need to know and we should reply in a fair and honest way without trying to dupe you with legalese. That seems pretty reasonable to us.

4.2. Information to be Provided

Here’s what we need to tell you when we ask you directly for any of your information :-

• contact details of the controller
  • Please contact us here if you require this information
• contact details of the data protection officer
  • At the moment we’re not required to have one but you can use the details above in the meantime
• the purposes of the processing
  • we need your contact details to reply to any requests you send us.  That’s it!
• the legitimate interests pursued by the controller 
  • we need your contact details to reply to any requests you send us.
• the recipients or categories of recipients of the personal data
  • We make use of the following services internally – Local Server Mail Services, Google Analytics (Site activity).
• if we “intend to transfer personal data to a third country or international organisation”
  • Other than the companies we’ve mentioned above we won’t share or sell your information to anyone

We are also required to tell you:-

• the period for which the personal data will be stored
  • Only as long as it takes for us to receive and reply to your email request.  At the point we answer your question your original email to us will be removed from our servers.
• that you have the following rights (please email us by clicking here and inform us of the right you wish to exercise) 
  • request access
  • rectification or erasure of personal data 
  • restriction of processing
  • object to processing
  • data portability
  • withdraw consent at any time
  • lodge a complaint with a supervisory authority
• whether 
  • the provision of personal data is a “statutory or contractual requirement, or a requirement necessary to enter into a contract” 
    • we do not ask you to sign any contract with us
  • you are “obliged to provide the personal data and of the possible consequences of failure to provide such data”
    • No, you’re not obliged to provide the data to us however it will be impossible for us to reply to your request without it
• the “existence of automated decision-making, including profiling”
  • We use Google Analytics as described above.  This helps us monitor who is using our site and determine if it’s at rick to external hacking attempts.  Google Analytics specifically obscure (obfuscate) details that it stores and information can only be seen down to the city level. It can not be used to specifically identify anyone

4.3. Right to Rectification

Where there are omissions in the data we hold you have the following two rights :-

• “inaccurate data corrected”
• “incomplete personal data completed”

We’re not currently recording any data on any requests may to us other than during the period that the requests remain unanswered.  This data will be removed at the point at which we answer your request so the time period for it to be inaccurate or incomplete should be in normal operation very short

4.4. Right to be Forgotten

We can do this where :-

• “Retention of personal data is no longer necessary” for the processing we told you we would carry out on it
• you specifically :-
  • “withdraw consent” – see above
  • “object to processing” – see above
• your data has been “unlawfully processed “
• your data has to be “erased as part of a legal obligation”

Your data is removed at the point we answer your request and at that point you’ll be forgotten by us anyway

4.5. Right to Restriction

Under this article you have the right to request restriction of processing where :-

• “data accuracy is contested”
• you oppose the “erasure [of data] and request restriction instead”
• we “no longer need the data for intended purpose”
• you “object to being processed by automated decision making”  Note that we don’t do any automatic decision making.  Paypal and Stripe, our Payment Gateways, may do this to ascertain your ability to pay for our services that you are subscribing to.  If you object to this and would like to pay for the services do contact us at the above address

We’ll store your data when you request us to restrict it and will tell you if this restriction is going to be lifted if restriction has be previously requested for legal reasons

4.6. Right to Object

There’s a couple of specific clauses we’re obliged to tell you about.  Here they are.

• You have the right to object to processing of personal data for “direct marketing including profiling related to direct marketing”
• Where you object your “personal data will no longer be processed for direct marketing”
• You will be told of your “right to object to processing”  Please consider us doing that here