1 – Our Core Believes Regarding User Privacy and Data Protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
2 – Relevant Legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- Australian Privacy Act 1988 (APA)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in?section 9.0) for clarification.
3 – Personal Information That This Website Collect and Why We Collect It
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see?section 6.0?below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
In addition to Google Analytics, this website?may collect* information (already held in the public domain) attributed to the IP address of the computer or device that is being used to access it.?The information is supplied to us from?Whoisvisiting.com. Whoisvisiting.com is a service offered by Whoisdata Limited.?The Whoisvisiting system does not use your IP address to identify you, the individual, in any way. No cookies are used by the Whoisvisiting system.
* The Whoisvisiting system will only lookup information when a static IP address is being used.?Differences between a static and dynamic IP address.
More information about?how Whoisvisiting uses IP addresses.
3.2 Contact forms and email links
Should you choose to contact us using the contact form on our?Contact us page?or an email link like?this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in?section 6.0. Instead the data will be collated into an email and sent to us over the?Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by?TLS?(sometimes known as SSL) meaning that the email content is encrypted using?SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always?consider email as an insecure medium?and not include personal, confidential or otherwise sensitive information within an email.
3.3 Email 顺心彩票letter
If you choose to join our email 顺心彩票letter, the email address that you submit to us will be forwarded to?MailChimp?who provide us with email marketing services. We consider MailChimp to be a third party data processor (see?section 6.0?below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email 顺心彩票letters that we send you or by?requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you?MUST?obtain parental consent before joining our email 顺心彩票letter.
While your email address remains within the MailChimp database, you will receive periodic 顺心彩票letter-style emails from us.
4 – How We Store Your Personal Information
As detailed in?section 3.2?above, if you submit a form on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (WordPress). In the near future we?aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to?keeping it as a high priority and will implement it on this website as soon as we are able to.
5 – About This Website’s Server
This website is hosted by?Savvii
All traffic (transferral of files) between this website and your browser is encrypted and delivered over?HTTPS.
6 – Our Third-Party Data Processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in?section 2.0.
7 – Data Breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach?if it is apparent that personal data stored in an identifiable manner?has been stolen.
8 – Data Controller
The data controller of this website is: Groundsailer Media B.V., a Dutch Private limited Company with company number: 66371295
Whose registered office is:
ALKMAAR, 1815 CC
9 – Data Protection Officer
Mr. Sake Marijn Rietveld
Director, Groundsailer Media B.V.
Telephone: + 31 6 0816 90 816
11 – Governing Law
This agreement shall be construed and enforced in accordance with the laws of The Netherlands.
Groundsailer Media B.V. is listed in the trade register of the Chamber of Commerce in Alkmaar, The Netherlands, under number 66371295.