THIS POLICY WAS UPDATED ON 29 May 2018.
What this policy contains:
- Information about us
- What Does This Policy Cover?
- A quick summary
- Your Rights
- Our legitimate interests
- What data do we collect?
- Location Information
- Information From Cookies & Other Technologies
- Newsletter Subscription Information
- Data Collected At Sign-Up
- What other data may we collect?
- How We Use your data
- How and Where Do We Store Your Data?
- Do we share your data?
- How long do we keep your data?
- How Can You Control Your Data?
- Your Right to Withhold Information
- Controlling Use of Your Data
- How Can You Access Your Data?
- Third Party Websites and Services
- Links to Other Websites
- Definitions and Interpretation
- “UK and EU Cookie Law”
- Scope of this Policy
- Changes of Business Ownership and Control
- Changes to this Policy
Terry Freedman Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
Please see the Appendix for definitions of the terms used in this policy.
Information about us
Our websites are is owned and operated by Terry Freedman Ltd, a limited company registered in England under company number 05145850, whose registered address is:
Our UK Data Protection Registration Number is Z8894247. We do not have a Data Protection Officer because, as a micro business, we are exempted from the need to have one. We can be contacted in the following ways:
Telephone: +44 (0) 191 645 1046
What Does This Policy Cover?
A quick summary
- We have legitimate interests for collecting your data, such as Consent, when you subscribe to one of our newsletters.
- You can control the data we collect, to some extent, such as by not allowing cookies.
- You may unsubscribe from our newsletters quickly and easily by clicking on the Unsubscribe link at the bottom of the newsletters.
- You may make a data request at any time.
- You may ask for your data to be deleted.
As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:
- The right to be informed about our collection and use of personal data;
- The right of access to the personal data we hold about you (see below under ‘How can you access your data?’);
- The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in the section entitled ‘Information about us’);
- The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you, from subscriptions, contests and surveys (we only hold your personal data for a limited time, as explained in the section entitled ‘How long do we keep your data?’);
- The right to restrict (i.e. prevent) the processing of your personal data. For example, we do not usually ask you to provide your name or email address in surveys. Please note, though, that we will not be able to provide certain services without these details, such as newsletters or prize draw wins;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to us using your personal data for particular purposes; please note that we will only use your personal data for the reasons stated below and
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided in the section entitled ‘Information about us’ and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Our legitimate interests
- Consent, when you subscribe to one our newsletters; for example, we will use your data to send you newsletters containing items such as those listed on https://www.writersknowhow.org/newsletters/ and https://www.ictineducation.org/diged/.
- Consent when you take part in a survey or poll
- Keeping our records up to date
- Working out which of our products and services may interest you and telling you about them
- Seeking your consent when we need to contact you
- Enabling us to fulfill our legal and contractual duties
What data do we collect?
Our website service, Squarespace, determines the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our website from certain geographic regions. Please also see below under Newsletter subscription information.
Information From Cookies & Other Technologies
Newsletter Subscription Information
The first thing to note, once again, is that although data is collected on individuals, we only ever look at the overall stats. For example, we are interested in how many people in total open an email message, but not in whether you personally opened it (no offence!). That tells us whether the subject matter (as announced in the subject header) is what many people are interested in.
Similarly, if we include links to websites or other resources, it’s interesting to see which ones get clicked on the most, because that gives me an idea of what sort of things people are interested in.
Also, we use a double opt-in system, which means that before subscribing you have to confirm that you really do want to.
In addition, it is very easy for you to unsubscribe at any time: just click the link at the bottom of the message.
Data Collected At Sign-Up
This is the data that is collected about you when you sign up, along with an explanation of what it means and why it’s useful, where that isn’t obvious:
- Full Name
- First Name
- Last Name
- Email Address
- Sign-up page
- Signup Date
- IP Address -- This is the address of your device, and from this the mailing company derives geolocation information. It’s useful for us to tell how many subscribers we have from different countries, which enables us to tailor the content accordingly. When subscribers opt in to the list, the mailing list company captures their IP address. Based on this IP address, for most subscribers the mailing list company can capture geographic information which we can use to personalize your messages. This geographic data is based on the subscriber's IP address, which will not always match where they are physically located. It is an approximate measure.” (There is more information about this on this aWeber page.)
There’s more information about IP addresses and geographic information here.
The IP address is also used in order to record unique opens and clicks. What this means is that if, say, an issue of the newsletter is opened three times by someone at the same IP address, the software assumes that it was opened by one person rather than three.
Data collected when you receive an emailed newsletter
- When you received the email.
- Whether you opened the email, and if so when.
- Whether you clicked on link.
This sort of data enables us to try and tailor the content and timing of the newsletter to best suit our subscribers (see below under 'How we use information'). We may collect other data from time to time, such as through surveys or amendments to the newsletter sign-up form (see below under Data Collected).
We use MailerLite to manage our email marketing subscriber list and to send emails to our subscribers. MailerLite is a third-party provider, which may process your data using industry standard technologies to help us monitor and improve our newsletter. They are based in the EU.
You can unsubscribe from our newsletter by clicking on the unsubscribe link provided at the end of each newsletter.
What other data may we collect?
From time to time we carry out user surveys to help us provide the services our readers want. The data collected in such services includes some or all of the following:
- age group
- job title;
- purchasing power;
- contact information such as email addresses and telephone numbers;
- demographic information such as post code, preferences and interests;
- financial information such as credit / debit card numbers;
- VAT number;
- Marketing preference;
- Where you heard of us;
- Why you visited or subscribed to this site or subscribed to one of our newsletters;
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
- a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected).
How We Use your data
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see ‘How and where we store your data’, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our products AND/OR services to you (please note that we require your personal data in order to enter into a contract with you);
- Personalising and tailoring our products AND/OR services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the Unsubscribe link at the bottom of our newsletters;
- Market research;
- Analysing your use of our site and gathering feedback to enable us to continually improve Our Site and your user experience;
- To provide our services, especially our newsletters, if you sign up to them, and relevant articles (the popularity of different topics, as shown by the number of times an article is looked at).
- To further develop our services–for example by adding new features or including new content that we think our users will enjoy based on the usage information.
- To monitor and analyze trends and better understand how users interact with our services, which helps us improve our services and make them easier to use.
- To communicate with you about offers and promotions we think will be of interest to you (such as new books available, prize draws and so on), solicit your feedback, or keep you up to date on our products.
Please note: we don't send different newsletters according to any interest you've expressed in particular topics or products by clicking on links; so you won't be sent targetted advertising or marketing.
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email information, news and offers on our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Third parties (including Feedblitz, Google Analytics, Payhip, Amazon, Kobo, csPoller, csFormbuilder, Google Forms) whose content appears on our site may use third party cookies, as detailed on the cookies page. Please refer to that page for more information on controlling cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
You have the right to withdraw your consent to us using your personal data at any time, and to request that We delete it.
How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above and/or for as long as We have your permission to keep it.
Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using our site and submitting information to Us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR by seeking reassurance that the 3rd party services we use are GDPR-compliant.
Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our site.
Steps We take to secure and protect your data include keeping backed-up subscriber data (we run a backup once a month) in a passworded and hidden folder on a pc, deleting IP addresses from surveys and polls results and, as far as is feasible, names and email addresses if these were collected. (Please note: by ‘feasible’ is meant the following: if someone offers to become an advance reader, for instance, then it would not be feasible to delete the name and email address, because we would not then be able to send them advance copies of a book. However, it would normally be feasible to delete their name and email address from survey results, unless their comments or questions requires a response or clarification.)
Do we share your data?
- We do not sell our users’ private personal information.
- We don’t pass it on to anyone else, unless we were legally obliged to. The only exception to this is as follows: if you enter a prize draw and you win, and the prize is something physical like a book, then we will need to pass your name and address to the organisation that will be sending the prize.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
- We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
How long do we keep your data?
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
Subscriber data: for as long as you are subscribed. . If you unsubscribe, or ignore an invitation to subscribe, we delete your data as soon as possible, and certainly within 30 days. If you unsubscribe, it may take a short while for your details to be deleted from our mailing service's server.
Competition entry data: for as long as it takes to confirm a winner, which we aim to do within a week. Please note, however, that in the event of the winner not responding to our email, we run the draw again using the same data. This happens within 10 working days of the initial draw. See the document on how we conduct prize draws for information about we dispose of the data collected.
Survey data, anonymised: for as long as we need to analyse the data. Our policy is to make it optional to provide a name and email address, and if the IP address is collected through a survey form we delete it before we analyse the results.
Contractual data: for as long as we are legally obliged to do so, which at the moment is 7 years.
How Can You Control Your Data?
You may opt out of receiving newsletters from us by unsubscribing using the links provided in our emails and at the point of providing your details.
You may also wish to sign up to the Mailing Preference Service (“the MPS”). This may help to prevent you receiving unsolicited marketing. Please note, however, that this service will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information
You may access most areas of our site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
Controlling Use of Your Data
Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
use of Data for direct marketing purposes; and sharing Data with third parties. However, please be assured that our policy is to not share personal data with third parties. Even our on-site surveys will usually include a question asking if it is OK to quote you.
Please see the following section also.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held, which will be through subscribing to our newsletters or responding to surveys or polls). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the information provided in the section entitled ‘Information about us’.
By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Please see our cookies page for more details. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a <<insert description of prompt, e.g. pop-up>> requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies by Squarespace; however certain features of Our Site may not function fully or as intended. You can also restrict cookies in the manner described on our cookies page. Please also see the cookies page for details of cookies which may be placed on your computer or device.
Our Site uses analytics services provided by Squarespace, Google Analytics and built-n analytics services where appropriate. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products AND/OR services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Please see our cookies page for more details.
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. Please see our cookies page for more details.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Third Party Websites and Services
Terry Freedman Ltd may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services would not normally have access to certain personal data provided by users of this website. Any data used by such parties would be used only to the extent required by them to perform the services that Terry Freedman Ltd requests. Any use for other purposes is strictly prohibited. Furthermore, any data that is processed by third parties must be processed within the terms of this Policy and in accordance with the GDPR.
Links to Other Websites
This Policy applies as between you, the User of this Website and Terry Freedman Ltd of Priestley House, Priestley Gardens, Chadwell Heath, Essex, RM6 4SN , the owner and provider of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our websites or surveys. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in Clause 12;
“UK and EU Cookie Law”
means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
means any third party that accesses the Website and is not employed by Terry Freedman Ltd and acting in the course of their employment; and
means the website that you are currently using and any sub-domains of that site unless expressly excluded by their own terms and conditions.
Scope of this Policy
This Policy applies only to the actions of Terry Freedman Ltd and Users with respect to our own Websites. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
Changes of Business Ownership and Control
Terry Freedman Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Terry Freedman Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
In the event that any Data submitted by Users is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.
Changes to this Policy
Terry Freedman Ltd reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.