Privacy Policy...
- Introduction
- Credit
- How we use your personal data
- Providing your personal data to others
- International transfers of your personal data
- Retaining and deleting personal data
- Amendments
- Your rights
- About cookies
- Cookies that we use
- Cookies used by our service providers
- Managing cookies
- Our details
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors
and customers.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and customers; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.4 In this policy, "we", "us" and "our" refer to Diviniti Publishing Ltd.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 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.
3.2 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 and Shopify. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. 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.
3.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.5 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.6 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 offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
3.8 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 consent.
3.9 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.10 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.
3.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.
3.13 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and
all its subsidiaries) insofar as reasonably necessary for the purposes, and
on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose notification data to our supplier iContact (https://www.icontact.com) insofar as reasonably necessary for us to manage and organise our mailing list and newsletters. You can find information about iContact's privacy policies and practices at https://www.icontact.com/legal/privacy
4.4 Financial transactions relating to our website and services are handled
by our payment services providers (Stripe, Worldpay, Shopify Pay, Apple
Pay, Google Pay, Coinbase and SendOwl). We will share transaction data with
our payment services providers only to the extent necessary for the
purposes of processing your payments, refunding such payments and dealing
with complaints and queries relating to such payments and refunds. You can
find information about the payment services providers' privacy policies and
practices at:
Apple Pay:
https://support.apple.com/en-gb/HT203027
Shopify:
https://www.shopify.com/legal/privacy
Stripe:
https://stripe.com/gb/privacy
SendOwl:
https://www.sendowl.com/privacy
Google Pay:
https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en
WorldPay:
https://www.worldpay.com/uk/privacy-policy
PayPal:
https://www.paypal.com/en/webapps/mpp/ua/privacy-full
Coinbase:
https://www.coinbase.com/legal/privacy?locale=en
4.5 In addition to the specific disclosures of personal data set out in this Section 4, 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.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in
which your personal data may be transferred to countries outside the
European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in the United Kingdom and United States. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
5.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 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.
6.2 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.
6.3 We will retain your personal data as follows:
(a) All data will be retained for a minimum period of 5 years and for a maximum period of 10 years following its submission to us.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of data will be determined based on the need to login and use our services or access purchased digital products.
6.5 Notwithstanding the other provisions of this Section 6, 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.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version
on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under
data protection law. Some of the rights are complex, and not all of the
details have been included in our summaries. Accordingly, you should read
the relevant laws and guidance from the regulatory authorities for a full
explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to
which you are party or in order to take steps at your request prior to
entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us.
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 do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website;
(b) status - we use cookies to help us to determine if you are logged into our website;
(c) personalisation - we use cookies to store information about your preferences and to personalise the website for you;
(d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(e) analysis - we use cookies to help us to analyse the use and performance of our website and services; and
(f) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally. You can manage your cookie settings for this website by adjusting your browser settings (instructions on this are set out below in 'Section 12. Managing Cookies').
11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on
your computer when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy
11.3 On our sister website www.hypnosisaudio.com we use Shopify. This service uses cookies to operate our ecommerce store, take orders and manage your account with us. You can view the privacy policy of this service provider at https://www.shopify.com/legal/privacy
11.4 On our sister website www.hypnosisaudio.com we use Sendowl. This service uses cookies to operate our digital download system and secure digital files. You can view the privacy policy of this service provider at https://www.sendowl.com/privacy
11.5 On our sister website www.hypnosisaudio.com we use Affilatly. This service uses cookies to operate our affiliate tracking system. You can view the privacy policy of this service provider at https://www.affiliatly.com/terms-of-use-and-privacy-statement.html
11.6 We use iContact. This service uses cookies to operate our mailing list system and send out our newsletters and offers. We can track, at an individual level, whether the user has opened and clicked on an email. We do not use this information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. If you want to be sure that none of your email activity is tracked then you should opt out of our emails which you can do via the unsubscribe link at the bottom of every email we send. You can view the privacy policy of this service provider at https://www.icontact.com/legal/privacy
11.7 We use social media buttons on this website. These cookies are set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks. Cookies are currently set by Twitter, Google & Facebook.
In order to implement these buttons, and connect them to the relevant social networks and external sites they may use scripts from domains outside of our website. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this website.
You should check the respective policies of each of these sites to see how
exactly they use your information and to find out how to opt out, or
delete, such information. You can view the privacy policy of these service
providers at:
Facebook:
https://www.facebook.com/full_data_use_policy
Twitter: https://twitter.com/en/privacy
Google:
https://www.google.com/policies/privacy
11.8 We use Facebook Pixel by Meta Platforms (Meta). This allows us to display interest-based advertisements (“Facebook Ads”) to users of the website when they visit the social network “Facebook” or other websites also using this tool. In this way, we pursue the interest in displaying advertisements that are of interest to you in order to make our website or offers more interesting for you. We also use the Facebook Pixel and the Conversions API to ensure that our Facebook Ads match the potential interest of users. With the help of the Facebook Pixel, we can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”). You can read about Facebook's privacy policy here: https://www.facebook.com/privacy/policy
11.9 We use Wordpress. The Blog and Forum section of this website runs the popular WordPress CMS and cookies are used to store basic data on your interactions, and whether you have logged into WordPress. We use a session cookie to remember your log-in for you if you are a registered user and we deem these as being strictly necessary to the working of the website. If these are disabled then various functionality on the site will be broken. More information on session cookies and what they are used for at www.allaboutcookies.org/cookies/session-cookies-used-for.html
11.10 If you click a link to our sister website www.hypnosisaudio.com we use cookies to track the items in your basket as you navigate from page to page. We also use these cookies to remember who you are when you log in and register with us. You can view the privacy policy of this service provider at https://www.hypnosisaudio.com/pages/privacy
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?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/HT201265 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
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 our website.
13. Our details
13.1 This website is owned and operated by Diviniti Publishing.
13.2 We are registered in England and Wales under registration number 3839308, and our registered office is at:
Diviniti Publishing Ltd,
Unit 1 Bourne Enterprise Centre,
Wrotham Road,
Borough Green,
Kent, TN15
8DG.
13.3 Our principal place of business is at the address above.
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on +44 (0)1732 882057; or
(d) by email on our contact page.