1.0 OUR CORE BELIEFS 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
2.0 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)
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 10.0) for clarification.
3.0 PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS 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 7.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
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 7.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our 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.
3.3 Email newsletter
If you choose to join our email newsletter, 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 7.0 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 newsletters 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.
While your email address remains within the MailChimp database, you will receive periodic (approximately three times a year) newsletter-style emails from us.
4.0 CUSTOMER RELATIONSHIP MANAGEMENT
Should Affari gather your personal information, by means detailed in section 3.0 (additionally, via our business development and marketing activity) we may store your information on our CRM system, Capsule, under Article 6 of the GDPR, Lawful Basis for Processing. We consider Capsule to be a third party data processor (see section 7.0).
Your information will remain within Capsule’s database for as long as we continue to use Capsule’s services for customer relationship management or until you specifically request removal from our records. You can do this by requesting removal via email.
5.0 LEGITIMATE BUSINESS PURPOSES
We process personal information for certain legitimate business purposes, which include some or all of the following:
- Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers
- To better understand how people interact with our websites
- To provide postal communications which we think will be of interest to you
- To determine the effectiveness of promotional campaigns and advertising.
Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please click here. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.
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.
7.0 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. Mailchimp, Google and GoDaddy are based in the USA and are EU-U.S Privacy Shield compliant.
8.0 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.
9.0 DATA CONTROLLER
The data controller of this website is: Affari Media Ltd, a UK Private limited Company with company number: 08088909
Whose registered office and operating office is:
NBV Enterprise Centre,
6 David Lane,
11.1 CHANGE LOG
19.04.2018 – Version 1.0 published