1. Introduction
We are committed to safeguarding the privacy of our service users.
This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.
We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
In this policy, "we", "us" and "our" refer to Journalmind Ltd. For more information about us, see Section 8.
2. How we use your personal data
In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
We may process data about your use of our 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 Google Analytics. This usage data may be processed for the purposes of analysing the use of our website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process your website user account data ("account data"). The account data may include your email address, and "other" data such as your journal entries and files. The source of the account data is you, and is provided when you sign up for and use our services. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of customer support, and providing you with our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details and the transaction details. The source of the transaction data is you and/or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased goods and/or services and keeping proper records of those transactions. The legal basis for this processing is the proper administration of our website and business, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users.
We may process any of your personal data identified in this policy 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 our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
Your personal data held in our database will be stored on the servers of our hosting services providers Amazon Web Services identified at https://aws.amazon.com.
Your personal data held by our payment provider will be stored on the servers of our payment provider Chargebee identified at https://www.chargebee.com.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We 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.
4. Retaining and deleting personal data
This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
(a) usage data will be retained for a minimum period of 26 months following the date of collection, and for a maximum period of 1 month following that date;
(b) account data will be retained for a minimum period of 3 years following the date of closure of the relevant account, and for a maximum period of 6 months following that date, subject to periodic reviews;
(c) enquiry data will be retained for a minimum period of 3 months following the date of the enquiry, and for a maximum period of 3 years following that date;
(d) transaction data will be retained for a maximum period of 3 months following the date of termination of the subscription belonging to the relevant account;
(e) notification data will be retained for a minimum period of 1 year following the date that we are instructed to cease sending the notifications, and for a maximum period of 6 months following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications).
Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. Your rights
In this Section 5, we have listed the rights that you have under data protection law.
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 us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask use 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 we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
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.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
6. Cookies used by our service providers
Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners and you can review Google's privacy policy at https://policies.google.com/privacy.
7. Amendments
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We will notify you of significant changes to this policy by email.
8. Our details
This website is owned and operated by Journalmind Ltd.
We are registered in Scotland under registration number SC643584, and our registered office is at Suite 4F, Ingram House, 227 Ingram Street, Glasgow, G1 1DA, Scotland.
You can contact us:
(a) by post, to the postal address given above;
(b) using our website support centre; or
(d) by email, using support@journalmind.com.
9. Credit
This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).