Privacy Policy

Introduction

I respect your privacy and am committed to protecting your personal data. This privacy policy will inform you as to how I look after your personal data when you visit my website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please use the Glossary to understand the meaning of some of the terms used in this policy

​1. Important information

​Purpose of this privacy policy

This privacy policy aims to give you information on how I collect and process your personal data through your use of this website.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy that may be provided from time to time when personal data is collected or processed about you so that you are fully aware of how and why your data is being used.

​Controller

I am the controller and responsible for your personal data.

​Contact details

If you have any questions about this privacy policy, please contact me in the following way:

Name: Freya McMillan

Email address: freya@freyawrites.com  

​You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to address your concerns before you approach the ICO so please contact me in the first instance. 

​Changes to the privacy policy and your duty to inform me of changes

I keep my privacy policy under regular review. This version was last updated on 22nd August 2021.

​It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and am not responsible for their privacy statements. When you leave this website, please read the privacy policy of every website you visit.

2. The data that is collected about you

​Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

​I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  
  • Usage Data includes [nformation about how you use our website, products and services. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

I may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

​I do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do I collect any information about criminal convictions and offences.

If you fail to provide personal data

Where I need to collect personal data by law, or under the terms of a contract and you fail to provide that data when requested, I may not be able to perform the contract I have or am trying to enter into with you (for example, to provide you with goods or services). In this case, I may have to cancel a product or service but I will notify you if this is the case at the time. 

3. How is your personal data collected?

​I may use different methods to collect data from and about you including through:

  • Direct interactions. You may give me your identity and contact by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:
    • subscribe to service or publications; 
    • request marketing to be sent to you;
    • contribute to my blog (such as, but not limited to interviews or guest articles)
    • enter a competition, promotion or survey; or
    • give feedback or contact me.
    • Automated technologies or interactions. As you interact with my website, Technical Data will be automatically collected about your equipment, browsing actions and patterns. This personal data is collected by using cookies, server logs and other similar technologies. 
  • Third parties or publicly available sources. Personal data will be received about you from various third parties and public sources as set out below: 
  • Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU/UK; 

(b) advertising networks based inside OR outside the EU/UK; and

(c) search information providers based inside OR outside the EU/UK.

​4. How your personal data is used

I will only use your personal data when the law allows. Most commonly, I will use your personal data in the following circumstances:

  • Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where I need to comply with a legal obligation.

Generally, I do not rely on consent as a legal basis for processing your personal data although I will obtain your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting me.

​Purposes for which I will use your personal data

Under the GDPR (General Data Protection Regulation) I control and or process any personal information about you electronically using the following lawful basis.

  • I am exempt from registration in the ICO Data Protection Register because your data is only processed for the core purpose of managing this website and my role as an author and writer.
  • Lawful basis: Legitimate interests
    Where my purpose for processing is: As described above.
    Which is necessary because: It assists in building a community which is fundamental to this website.
    I process your information in the following ways: Via comments, via a contact form or via a newsletter.
    Data retention period: I will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
    Sharing your information: I do not share your information with third parties.

You will receive marketing communications from me if you have requested information from me or purchased goods or services from me and you have not opted out of receiving that marketing.

​Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

Change of purpose 

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me. 

​If I need to use your personal data for an unrelated purpose, I will notify you and explain the legal basis which allows me to do so.

Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

​5. International transfers

​I do not transfer your personal data outside the UK or EEA.

6. Data security

​I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

​7. Data retention

​How long will you use my personal data for?

I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation.

​In some circumstances you can ask me to delete your data, as set out in the website of the Office of the Information Commissioner.

8. Your legal rights

​Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the website of the Office of the Information Commissioner.

What I may need from you

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

I aim to respond to all legitimate requests within one month. Occasionally it could take longer if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated. 

​9. Glossary

​LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable me to give you the best service/product and the best and most secure experience. I make sure that I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for our legitimate interests. I do not use your personal data for activities where our interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess our legitimate interests against any potential impact on you in respect of specific activities by contacting me.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that I am subject to.

​THIRD PARTIES

External Third Parties

  • Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
  • Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in the United Kingdom who provide [consultancy, banking, legal, insurance and accounting services].
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based [in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

​Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.

Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.

Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: 

  • If you want me to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want me to erase it.
  • Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims. 
  • You have objected to our use of your data but I need to verify whether I have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you. 

Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.