- Introduction
1.1 Matthew Hutton (MH) as the author and copyright owner of the Book and the Website is committed to safeguarding the privacy of Website visitors to and service users of the Website.
1.2 This Policy applies where MH is acting as a data controller with respect to the personal data of such Website visitors and service users; in other words, where he determines the purposes and means of the processing of that personal data.
1.3 MH uses cookies on the Website. Insofar as those cookies are not strictly necessary for the provision of the Website and services, he will ask you to consent to his use of cookies when you first visit the Website.
- Use of your personal data
2.1 This Section 2 sets out:
(a) the general categories of personal data that MH may process;
(b) in the case of personal data that MH did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which MH may process personal data; and
(d) the legal bases of the processing.
2.2 MH may process data about your use of the 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 MH’s analytics tracking system. 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 MH’s legitimate interests, namely monitoring and improving the Website and services.
2.3 MH 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 or your employer. The account data may be processed for the purposes of operating the Website, providing MH’s services, ensuring the security of the Website and services, maintaining back-ups of MH’s databases and communicating with you. The legal basis for this processing is MH’s legitimate interests, namely the proper administration of the Website and business.
2.4 MH may process information relating to his customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between MH and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing MH’s relationships with customers, communicating with customers, keeping records of those communications and promoting MH’s products and services to customers. The legal basis for this processing is MH’s legitimate interests, namely the proper management of his customer relationships.
2.5 MH may process information relating to transactions, including purchases of goods and services, that you enter into with him (“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 MH and/or taking steps, at your request, to enter into such a contract and MH’s legitimate interests, namely the proper administration of his business.
2.6 MH may process information that you provide to him for the purpose of subscribing to his 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.
2.7 MH may process information contained in or relating to any communication that you send to him (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. The Website will generate the metadata associated with communications made using any 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 MH’s legitimate interests, namely the proper administration of the Website and business and communications with users.
2.9 MH 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 MH’s legitimate interests, namely the protection and assertion of his legal rights, your legal rights and the legal rights of others.
2.10 MH 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 MH’s legitimate interests, namely the proper protection of his business against risks.
2.11 In addition to the specific purposes for which MH may process your personal data set out in this Section 2, MH may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which he is subject, or in order to protect your vital interests or the vital interests of another natural person.
2.12 Please do not supply any other person’s personal data to MH, unless you are prompted you to do so.
- Providing your personal data to others
3.1 MH may disclose your personal data to any business associate of his, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
3.2 MH may disclose your personal data to his 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.
3.3 MH may disclose your personal data to his suppliers or subcontractors insofar as reasonably necessary for them to conduct business on his behalf.
3.4 Financial transactions relating to services may be handled by MH’s payment services providers. MH will share transaction data with his 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.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, MH may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which he are subject, or in order to protect your vital interests or the vital interests of another natural person. MH 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. International transfers of your personal data
4.1 In this Section 4, MH provides information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom (UK).
4.2 MH may establish offices and facilities in countries outside the UK. 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 or other authorities.
4.3 The hosting facilities for the Website are situated in the United Kingdom. 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 or other authorities.
4.4 You acknowledge that personal data that you submit for publication through the Website or services may be available, via the internet, around the world. MH cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
5.1 This Section 5 sets out MH’s data retention policies and procedure, which are designed to help ensure that MH complies with his legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that MH processes for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, MH may retain your personal data where such retention is necessary for compliance with a legal obligation to which he is subject, or in order to protect your vital interests or the vital interests of another natural person.
- Security of personal data
6.1 MH will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 MH will store your personal data on secure servers, personal computers and in some instances mobile devices, and in secure manual record-keeping systems.
6.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and MH cannot guarantee the security of data sent over the internet.
- Amendments
7.1 MH may update this Policy from time to time by publishing a new version on the Website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this Policy.
7.3 MH may notify you of changes to this Policy by email.
- Your rights
8.1 In this Section 8, MH summarises 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 the 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 MH processes your personal data and, where he does, 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, MH 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; MH no longer needs the personal data for the purposes of MH’s 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, MH may continue to store your personal data. However, MH will otherwise process it only: 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 MH’s 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 MH; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, MH will cease to process the personal information unless he 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 MH’s processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, MH will cease to process your personal data for this purpose.
8.9 You have the right to object to MH’s 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 MH’s 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 MH 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 MH’s 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 MH’s 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 MH.
- Third party websites
9.1 The Website includes hyperlinks to, and details of, third party websites.
9.2 MH has no control over, and is not responsible for, the privacy policies and practices of third parties.
- Updating information
10.1 Please let MH know if the personal information that he holds about you needs to be corrected or updated.
- About cookies
11.1 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.
11.2 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.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that MH stores about you may be linked to the information stored in and obtained from cookies.
- Cookies that MH uses
12.1 MH uses cookies for the following purposes:
(a) authentication – MH uses cookies to identify you when you visit the Website and as you navigate the Website;
(b) status – MH uses cookies to help us to determine if you are logged into the Website;
(c) security – MH uses cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect the Website and services generally;
(d) analysis – MH uses cookies to help him to analyse the use and performance of the Website and services;
(e) cookie consent – MH uses cookies to store your preferences in relation to the use of cookies more generally.
- Cookies used by MH’s service providers
13.1 MH’s service providers use cookies and those cookies may be stored on your computer when you visit the Website.
13.2 MH uses Google Analytics to analyse the use of the Website. Google Analytics gathers information about Website use by means of cookies. The information gathered relating to the Website is used to create reports about the use of the Website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
- Managing cookies
14.1 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/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many Websites.
14.3 If you block cookies, you will not be able to use all the features on the Website.
- MH’s details
15.1 The Website is owned and operated by Matthew Hutton.
15.2 MH’s principal place of business is at Broom Farm, Chedgrave, Norwich NR14 6BQ
15.3 You can contact MH:
(a) by post, to the postal address given above; or
(b) by email, using the email address published on the Website.