1.1 I am committed to safeguarding the privacy of my website visitors.
1.2 This policy applies where I am acting as a data controller with respect to the personal data of such persons; in other words, where I determine the purposes and means of the processing of that personal data.
1.5 In this policy, “I”, “me” and “my” refer to Alexander Lane. For more information about me, see Section 14.
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that I collect
3.1 In this Section 3 I have set out the general categories of personal data that I process.
3.2 I may process data enabling me to get in touch with you “contact data“. The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you. If you log into my website using a social media account, I will obtain elements of the contact data from the relevant social media account provider.
3.3 I may process your website user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by my website. If you log into my website using a social media account, I will obtain elements of the account data from the relevant social media account provider.
3.5 I may process information contained in or relating to any communication that you send to me or that I send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. My website will generate the metadata associated with communications made using the website contact forms.
3.6 I may process data about your use of my 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 my analytics tracking system.
4. Purposes of processing and legal bases
4.1 In this Section 4, I have set out the purposes for which I may process personal data and the legal bases of the processing.
4.2 Operations – I may process your personal data for the purposes of operating my website. The legal basis for this processing is my legitimate interests, namely the proper administration of my website, services and business.
4.4 Relationships and communications – I may process contact data, account data and/or communication data for the purposes of managing my relationships, communicating with you by email, SMS, post, fax and/or telephone. The legal basis for this processing is my legitimate interests, namely communications with my website visitors, the maintenance of relationships, and the proper administration of my website, services and business.
4.6 Research and analysis – I may process usage data for the purposes of researching and analysing the use of my website and services, as well as researching and analysing other interactions with my business. The legal basis for this processing is consent OR my legitimate interests, namely monitoring, supporting, improving and securing my website, services and business generally.
4.7 Record keeping – I may process your personal data for the purposes of creating and maintaining my databases, back-up copies of my databases and my business records generally. The legal basis for this processing is my legitimate interests, namely ensuring that I have access to all the information I need to properly and efficiently run my business in accordance with this policy.
4.8 Security – I may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is my legitimate interests, namely the protection of my website, services and business, and the protection of others.
4.9 Insurance and risk management – I may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is my legitimate interests, namely the proper protection of my business against risks.
4.10 Legal claims – I may process your personal data 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 my legitimate interests, namely the protection and assertion of my legal rights, your legal rights and the legal rights of others.
4.11 Legal compliance and vital interests – I may also process your personal data where such processing is necessary for compliance with a legal obligation to which I am subject or in order to protect your vital interests or the vital interests of another natural person.
5. Providing your personal data to others
5.1 I may disclose your personal data to my insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.2 Your personal data held in my website database will be stored on the servers of my hosting services providers identified.
5.5 In addition to the specific disclosures of personal data set out in this Section 5, I may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person. I 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.
6. International transfers of your personal data
6.1 In this Section 6, I provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).
6.2 The hosting facilities for my website are situated in the Netherlands. The competent data protection authorities have made an “adequacy decision” with respect to the data protection laws of this country. Transfers to the Netherlands will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
6.4 You acknowledge that personal data that you submit for publication through my website may be available, via the internet, around the world. I cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 7 sets out my data retention policies and procedures, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 I will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 12 months following the date of the most recent contact between you and me, and for a maximum period of 10 years following that date;
(b) [account data will be retained for a minimum period of 12 months following the date of closure of the relevant account, and for a maximum period of 10 years following that date;
(d) communication data will be retained for a minimum period of 12 months following the date of the communication in question, and for a maximum period of 10 years following that date;
(e) usage data will be retained for up to 10 years following the date of collection; and
7.4 Notwithstanding the other provisions of this Section 7, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your rights
8.1 In this Section 8, I have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask me to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask me to erase your personal data;
(d) the right to restrict processing – you can ask me to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that I transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about my processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of my processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to me, using the contact form.
9. 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 may not contain any information that personally identifies a user, but personal data that I store about you may be linked to the information stored in and obtained from cookies.
9.4 If you leave a comment on my site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
9.5 If you visit my login page, I will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
9.6 When you log in, I will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
9.7 If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
10. Cookies that I use
11. Cookies used by my service providers
12. 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 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
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 my website.
13.1 I may update this policy from time to time by publishing a new version on my website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
13.3 I may notify you of significant changes to this policy by email.
14.1 When visitors leave comments on the site I collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
15.1 If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
16 Embedded content from other websites
16.1 Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
17. My details
17.1 This website is owned and operated by Alexander Lane.
17.2 You can contact me using my website contact form.
18. Data protection officer
18.1 I am the data protection officer.
18.2 You can contact me using my website contact form.