1.       Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website

1.3    In this policy, “we”, “us” and “our” refer to Corten Editorial.

2.       Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com).

3.       How we use your personal data

We may collect and process your personal data, as follows:

3.1    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.

3.2    We may process information contained in any enquiry or correspondence 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.

3.3    We may process your personal data that are provided in the course of the purchase and use of our services (“service data“). The service data may include name, company name, address, email address and telephone number and the transaction details.

3.3    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.

3.4    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.

3.5    Please do not supply any other person’s personal data to us, unless you have their express permission to do so and have disclosed the processing of personal data under this policy.

4.       Providing your personal data to others

4.1    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.

4.2    Except for the circumstances detailed in 4.1 and any instances where you provide specific express permission to provide information to a named third party, we will not provide your personal data to any third party.

5.       International transfers of your personal data

5.1    We host personal data on Microsoft’s OneDrive cloud storage facility. Microsoft has provided assurance that the appropriate measures will be put in place to ensure that its GDPR compliant when GDPR comes into force on 25th May 2018. Please refer to this article for details https://blogs.microsoft.com/on-the-issues/2017/02/15/get-gdpr-compliant-with-the-microsoft-cloud/.

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)    Where an enquiry has not progressed into the purchase of services, personal data (name, email address and/or telephone number) will be retained until the end of the tax year in which the enquiry occurred.

(b)    Where a service has been purchased, the personal data (name, email address, telephone number and billing address) will be retained for two full tax years after the end of the tax year in which the transaction took place (e.g. the personal data for a transaction in September 2018 will be retained until April 5th 2021).

6.4    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.

8.       Your rights

8.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the payment of a fee (currently fixed at GBP 10); and

(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2    We may withhold personal information that you request to the extent permitted by law.

8.3    You may instruct us at any time not to process your personal information for marketing purposes.

8.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

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)    Analysis – we use cookies to help us to analyse the use and performance of our website and services.; and

(g)    Cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

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.

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/kb/PH21411 (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.

13.    Our details

13.1  This website is owned and operated by Lindsay Corten, who is a sole trader.

13.2  You can contact us:

(a)    By telephone, on the contact number published on our website from 8am to 6pm, Monday to Friday; or

(d)    By email, using the email address published on our website.