[vc_row row_type=”row” use_row_as_full_screen_section=”no” type=”full_width” angled_section=”no” text_align=”left” background_image_as_pattern=”without_pattern” css_animation=””][vc_column width=”1/6″][/vc_column][vc_column width=”2/3″][vc_column_text]NEW KELLY WILCH 1/11/17

Privacy Policy

 

Your privacy is very important to us. We want to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet’s vast array of information, tools, and opportunities with complete confidence.

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our company collects information from all end users of our Internet services (the “Services”)-those who access some of our Services but do not have accounts (“Visitors”) as well as those who may purchase Products and/or pay a monthly service fee to subscribe to the Service (“Members”)-what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. We request that you read this Privacy Policy carefully. By visiting our Company Website, you are consenting to our policy of collecting and using your data.

Personal Information Our

Company Collects and How It Is Used

 

Introduction. Our company collects information in different ways from Visitors and Members who access the various parts of our Services and the network of Web sites accessible through our Service.

Registration: Members may be asked to provide certain personal information when they sign up for our Products or Services including name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process is used to manage each Member’s account (such as for billing purposes). This information may be shared with third parties, as stated herein, or in special circumstances.

However, in instances where our company and a partner jointly promote our Services, we may provide the partner certain personal information, such as the name, address, and username of persons who subscribed to the Services as a result of the joint promotion for the purpose of offering you other products and services.

We may also generate non-identifying and aggregate profiles from personal information Members provide during registration (such as the total number, but not the names, of Members). As explained in more detail below, we may use this aggregated and non- identifying information to sell advertisements that appear on the Services.

Our Company collects personal information through forms you complete on the site, as well as but not limited to contests, sweepstakes, text messages, e-mails, faxes, telephone calls, postal mail or other communications with the user, as well as from outside sources such as credit card processors and database vendors.

 

For example, when you fill out a form subscribing to our emails, we are sent data information from our autoresponder company such as your name, email, the website you signed up from, geographical data such as your city, state, Postal code, country, Latitude, Longitude, Timestamp, Subscription method and IP address.

Also, with purchases, we supply our member’s contact information, to our business partners, who then may contact the member by telephone after the member purchase. Sales proceeds are collected by that business partner company. We also may supply other companies with contact information, for mail offers we believe would be of interest to our members, with or without compensation from those companies. At times we may send an advertisement for a third party product, where we collect the sales proceeds and forward the purchaser’s information to that third party.

Our Company Partners and Sponsors: Some products and services may be offered to Visitors and Members in conjunction with an affiliate, independent contractor seller or non-affiliated partner. To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information.

Online Shopping: At some Web sites, you can purchase products and services or register to receive materials, such as a newsletter, catalog or new product and service updates. In many cases, you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information.

If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient’s name, address, and phone number. Our company has no control over the third parties’ use of any personal information you provide when placing such an order. Please exercise care when doing so.

If you order services or products directly from our company, we use the personal information you provide to process that order. We do share this information with outside parties that we do business with.

Online Advertisements: Our Company may display our online advertisements. In those cases, we share information about our Visitors and Members collected through the registration process as well as through online surveys and promotions with these advertisers.

Additionally, in some instances, we use this information to deliver tailored advertisements or joint ventures. For instance, an advertiser or joint venture company tells us the audience they want to reach and provides us an advertisement tailored to the audience. Based upon the information we have collected, we may then display or send the advertisement to the intended audience. Our company does share personal information about its Visitors or Members with these advertisers or joint venture companies.

 

By visiting our Company Website, you are consenting to our policy of collecting and using your data. If you do not want to consent to our policy of collecting and using your data you can “opt out” of our Social Network and Facebook.com Website Custom Audience Ads advertising policy by notifying Company in the following manner:

Social Network and Facebook.com Website Custom Audience Ads (WCA):

A Custom Audience on Facebook.com is a list of people our company would like to show our ads to on Facebook.com, who have shown interest in our products and services, with ads we believe would be of interest to them. This audience consists of people, whose information and email addresses our Company already has because they have already subscribed to receiving Company emails.

If you no longer have an interest in our products and services, you can opt-out of seeing Company’s Facebook.com Website Custom Audience Ads. Unsubscribing from our Company’s email list will remove you from Company’s internal email database list and stop future emails from our Company, but not from being shown Facebook.com Website Custom Audience Ads. The Facebook.com Website Custom Audience Ads external database is different from our Company’s internal database and requires the following Opting-out request.

Opting-out of Facebook.com Website Custom Audience Ads:

To opt out of our Company’s Facebook.com Custom Audience Ads, send an email, from the email address you are opting out, to Company using our email address provided in Company’s contact information. Put “Opting Out of Facebook.com Website Custom Audience Ads ” in the subject line of the email. In the body of the email include your name and email address. Our Company staff will forward your name and email address to Facebook.com with a request to delete you from all of Company’s Facebook.com Website Custom Audience Ads.

Google.com Analytics

Our Company may use Analytics tracking code to support Display Advertising, and enable Google Analytics to collect data about your traffic via the DoubleClick cookie in addition to data collected through the standard Google Analytics implementation. Display Advertising lets us enable features in Analytics that aren’t available through standard implementations, like Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting.

Our Company may use Remarketing with Google Analytics to advertise online:

This allows third-party vendors, including Google, to show your ads on sites across the Internet. Our Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website.

Our Company may implement Google Display Network Impression Reporting or the DoubleClick Campaign Manager:

Our Company and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services that are related to visits to your site.

Our Company may implement Google Analytics Demographics and Interest Reporting:

The data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics allows us to serve ads to you based on this data.

Opting-out of Google Analytics’ For The Web and Google Analytics for Display Advertising:

Users can opt-out of Google Analytics’ currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout/

Using the Ads Settings, users can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads athttps://www.google.com/settings/personalinfo

 

Retargeting Ad Campaigns and Persistent Identifiers:

Our Company may utilize various types of advertising that appear on our Company sites and services including ads on third party sites and services. Our Company may utilize categories of information, including names and email addresses, collected from users of our sites and services, as well as third-party of sites and services, in connection with the ads that are served. This advertising may include, but not limited to, contextual advertising, cookies, anonymous cookies, pixels, persistent identifiers, geo-location information, email opt in, search engine terms, behavioral advertising and/or retargeting advertising.

This type of advertising is a form of targeted advertising, to the specific individual who is visiting the Web site. These advertisements appear on websites or other media, including display ads, pop-up ads, and ads displayed in mobile browsers. Those advertisements are selected and served by automated systems based on the interests relevant to the user from the content displayed to the user, based on what the user is viewing.

Our Company does not conduct inquiries into the information collection practices of third parties that may collect information from users that leave our Web site. Our Company

 

may share customer information with third parties to process orders, for third party analytics and for marketing and advertising purposes.

Responses to Email Inquiries: When Visitors or Members send email inquiries to our company; the return email address is used to answer the email inquiry we receive.

Voluntary Customer Surveys: We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to you.

We may take the information we receive from individuals responding to our Customer Surveys and combine (or aggregate) it with the responses of other customers we may have, to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you and to develop new services and products. This aggregated; non- personally identifying information may be shared with third parties.

Special Cases: It is our company’s policy to use or share the personal information about Visitors or Members in ways described herein without additional notice or means to opt out except as noted herein, or otherwise prohibit such unrelated uses.

Also, we may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including: credit agencies, collection agencies, merchant database agencies, law enforcement, or to satisfy laws, such as the Electronic Communications Privacy Act, the Child Online Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy or Terms Of Service, or other user policies; to operate the Services properly; or to protect our company and our Members.

Notice to California Residents – Your California Privacy Rights

Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to Company, to the email address provided in our contact information and please include the phrase “California Privacy Request” in the subject line, the domain name of the Web site you are inquiring about, along with your

name, address, and email address. We will respond to you within thirty days of receiving such a request.

“Cookies” and How Our Company Uses Them. A “cookie” is a small data file that can be

 

placed on your hard drive when you visit certain Web sites. Our company may use cookies to collect, store, and sometimes track information for purposes stated herein as well as for statistical purposes to improve the products and services we provide and to manage our telecommunications networks.

Deleting Cookies: If you don’t want our Company’s cookies on your computer, to be used for the purposes stated herein, they are easy to delete.  Simply go

to http://www.aboutcookies.org/Default.aspx?page=2 for instructions.

Advertisers and partners may also use their own cookies. We do not control the use of these cookies and expressly disclaim responsibility for information collected through them.

Our Company Commitment to Children’s Privacy: Protecting children’s privacy is especially important to us. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. Therefore we restrict our Web site to persons thirteen years or older.

IF YOU ARE UNDER THIRTEEN YEARS OF AGE, YOU ARE NOT PERMITTED TO ACCESS THIS WEBSITE FOR ANY REASON. DUE TO THE AGE RESTRICTIONS FOR USE OF THIS WEBSITE, NO INFORMATION OBTAINED BY THIS WEB SITE, FALLS WITHIN THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA)  AND IS NOT MONITORED AS DOING SO.

Public Forums: Please remember that any information you may disclose in any Member Directory, or other public areas of our Web sites or the Internet, becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.

Our Company’s Commitment to Data Security: Services and Web sites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third- party “hackers” from illegally obtaining this information.

Where to Direct Questions About Our Privacy Policy: If you have any questions about this Privacy Policy or the practices described herein, you may contact us through the contact information provided on this Web site.

Revisions to This Policy: Our company reserves the right to revise, amend, or modify this policy, our Terms Of Service agreement, and our other policies and agreements at any time and in any manner, by updating this posting. Your use of this site after such changes are implemented constitutes your acknowledgment and acceptance of these changes.

Please consult this privacy statement prior to every use for any changes. Last updated: May 21, 2018 11th, 2018

 

 

Privacy policy

  1. Introduction

1.1   We are committed to safeguarding the privacy of [our website visitors and service users].

1.2   This policy applies where we are acting as a data controller with respect to the personal data of [our website visitors and service users]; in other words, where we determine the purposes and means of the processing of that personal data.

1.3   We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of [our website and services], we will ask you to consent to our use of cookies when you first visit our website.

1.4   Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can [specify whether you would like to receive direct marketing communications and limit the publication of your information]. You can access the privacy controls via [http://kellywilch.com].

1.5   In this policy, “we”, “us” and “our” refer to [KellyWilch.com].[ For more information about us, see Section 13.]

  1. Credit

2.1   This document was created using a template from SEQ Legal (https://seqlegal.com).

You must retain the above credit. Use of this document without the credit is an infringement of copyright. However, you can purchase from us an equivalent document that does not include the credit.

  1. How we use your personal data

3.1   In this Section 3 we have set out:

(a)   the general categories of personal data that we may process;

(b)   [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];

(c)    the purposes for which we may process personal data; and

(d)   the legal bases of the processing.

3.2   We may process [data about your use of our website and services] (“usage data“). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is [our analytics tracking system]. This usage data may be processed [for the purposes of analysing the use of the website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [monitoring and improving our website and services]] OR [[specify basis]].

3.3   We may process [your account data] (“account data“).[ The account data may [include your name and email address].][ The source of the account data is [you or your employer].] The account data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.] The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.4   We may process [your information included in your personal profile on our website] (“profile data“).[ The profile data may include [your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details].] The profile data may be processed for [the purposes of enabling and monitoring your use of our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract] OR [[specify basis]].

3.5   We may process [your personal data that are provided in the course of the use of our services] (“service data“).[ The service data may include [specify data].][ The source of the service data is [you or your employer].] The service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.6   We may process [information that you post for publication on our website or through our services] (“publication data“). The publication data may be processed [for the purposes of enabling such publication and administering our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.7   We may process [information contained in any enquiry you submit to us regarding goods and/or services] (“enquiry data“). The enquiry data may be processed [for the purposes of offering, marketing and selling relevant goods and/or services to you]. The legal basis for this processing is [consent] OR [[specify basis]].

3.8   We may process [information relating to our customer relationships, including customer contact information] (“customer relationship data“).[ The customer relationship data may include [your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer].][ The source of the customer relationship data is [you or your employer].] The customer relationship data may be processed [for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper management of our customer relationships]] OR [[specify basis]].

3.9   We may process [information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website] (“transaction data“).[ The transaction data may include [your contact details, your card details and the transaction details].] The transaction data may be processed [for the purpose of supplying the purchased goods and services and keeping proper records of those transactions]. The legal basis for this processing is [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely [the proper administration of our website and business]] OR [[specify basis]].

3.10 We may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] (“notification data“). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters]. The legal basis for this processing is [consent] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.11 We may process [information contained in or relating to any communication that you send to us] (“correspondence data“). The correspondence data may include [the communication content and metadata associated with the communication].[ Our website will generate the metadata associated with communications made using the website contact forms.] The correspondence data may be processed [for the purposes of communicating with you and record-keeping]. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website and business and communications with users]] OR [[specify basis]].

3.12 We may process [identify general category of data].[ This data may include [list specific items of data].][ The source of this data is [identify source].] This data may be processed for [specify purposes]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [specify legitimate interests]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.13 We 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 our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others].

3.14 We 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 our legitimate interests, namely [the proper protection of our business against risks].

3.15 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process [any of your personal data] where such processing is necessary[ for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.

3.16 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

4.1   We may disclose [your personal data] to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.[ Information about our group of companies can be found at [URL].]

4.2   We may disclose [your personal data] to [our insurers and/or professional advisers] insofar as reasonably necessary for the purposes of [obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure].

4.3   We may disclose [specify personal data category or categories] to [our suppliers or subcontractors][ identified at [URL]] insofar as reasonably necessary for [specify purposes].

4.4   Financial transactions relating to [our website and services] [are] OR [may be] handled by our payment services providers, [identify PSPs]. We will share transaction data with our payment services providers only to the extent necessary for the purposes of [processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds]. You can find information about the payment services providers’ privacy policies and practices at [URLs].

4.5   We may disclose [your enquiry data] to [one or more of those selected third party suppliers of goods and services identified on our website] for the purpose of [enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services].[ Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.]

4.6   In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.[ We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.]

  1. International transfers of your personal data

5.1   In this Section 5, we provide information about the circumstances in which your personal data may be transferred to [countries outside the European Economic Area (EEA)].

5.2   We[ and our other group companies] have [offices and facilities] in [specify countries].[ The European Commission has made an “adequacy decision” with respect to [the data protection laws of each of these countries].][ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from [source]] OR [the use of binding corporate rules, a copy of which you can obtain from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]

5.3   The hosting facilities for our website are situated in [specify countries].[ The European Commission has made an “adequacy decision” with respect to [the data protection laws of each of these countries].][ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]

5.4   [Specify category or categories of supplier or subcontractor] [is] OR [are] situated in [specify countries].[ The European Commission has made an “adequacy decision” with respect to [the data protection laws of each of these countries].][ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]

5.5   You acknowledge that [personal data that you submit for publication through our website or services] may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

  1. Retaining and deleting personal data

6.1   This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2   Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3   We will retain your personal data as follows:

(a)   [personal data category or categories] will be retained for a minimum period of [period] following [date], and for a maximum period of [period] following [date].

[additional list items]

6.4   In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)   the period of retention of [personal data category] will be determined based on [specify criteria].

[additional list items]

6.5   Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

7.1   We may update this policy from time to time by publishing a new version on our website.

7.2   You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3   We [may] OR [will] notify you of [changes] OR [significant changes] to this policy [by email or through the private messaging system on our website].

  1. Your rights

8.1   In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2   Your principal rights under data protection law are:

(a)   the right to access;

(b)   the right to rectification;

(c)    the right to erasure;

(d)   the right to restrict processing;

(e)   the right to object to processing;

(f)    the right to data portability;

(g)   the right to complain to a supervisory authority; and

(h)   the right to withdraw consent.

8.3   You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.[ You can access [your personal data] by visiting [URL] when logged into our website.]

8.4   You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5   In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].

8.6   In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7   You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8   You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9   You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a)   consent; or

(b)   that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data [by written notice to us] OR [by [methods]][, in addition to the other methods specified in this Section 8].

  1. About cookies

9.1   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.

9.2   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.

9.3   Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that we use

10.1 We use cookies for the following purposes:

(a)   [authentication – we use cookies [to identify you when you visit our website and as you navigate our website][ (cookies used for this purpose are: [identify cookies])]];

(b)   [status – we use cookies [to help us to determine if you are logged into our website][ (cookies used for this purpose are: [identify cookies])]];

(c)    [personalisation – we use cookies [to store information about your preferences and to personalise the website for you][ (cookies used for this purpose are: [identify cookies])]];

(d)   [security – we use cookies [as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally][ (cookies used for this purpose are: [identify cookies])]];

(e)   [advertising – we use cookies [to help us to display advertisements that will be relevant to you][ (cookies used for this purpose are: [identify cookies])]];

(f)    [analysis – we use cookies [to help us to analyse the use and performance of our website and services][ (cookies used for this purpose are: [identify cookies])]]; and

(g)   [cookie consent – we use cookies [to store your preferences in relation to the use of cookies more generally][ (cookies used for this purpose are: [identify cookies])]].

  1. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

11.3 [We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies.] OR [We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website).] You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996

11.4 We use [identify service provider] to [specify service]. This service uses cookies for [specify purpose(s)]. You can view the privacy policy of this service provider at [URL].[ The relevant cookies are: [identify cookies].]

  1. Managing cookies

12.1 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?hl=en (Chrome);

(b)   https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)   https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)   https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

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12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

  1. Our details

13.1 This website is owned and operated by [name].

13.2 We are registered in [England and Wales] under registration number [number], and our registered office is at [address].

13.3 Our principal place of business is at [address].

13.4 You can contact us:

(a)   [by post, to [the postal address given above]];

(b)   [using our website contact form];

(c)    [by telephone, on [the contact number published on our website from time to time]]; or

(d)   [by email, using [the email address published on our website from time to time]].

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  1. Data protection officer

14.1 Our data protection officer’s contact details are: dkwilch@gmail.com