Last updated: 27 April 2018
By Maynard Paton
1.1 In this policy, “I”, “me” and “my” refer to Maynard Paton and “website” refers to maynardpaton.com.
1.2 I am committed to safeguarding the privacy of the visitors to the website.
1.3 This policy applies where I am acting as a data controller with respect to the personal data held by the website; in other words, where I determine the purposes and means of the processing of that personal data.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How I use your personal data
3.1 In this Section 3 I set out:
(a) the general categories of personal data that I may process;
(b) in the case of personal data that I did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which I may process personal data; and
(d) the legal bases of the processing.
3.2 I may process data about your use of the website (“usage data“). The usage data includes 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 use of the website. The source of the usage data is a combination of Unix server logs, Google Analytics, Wordfence Security software and CleanTalk spam-protection service. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is my legitimate interests, namely monitoring, improving and protecting the website.
3.3 I may process information that you submit for publication on my website (“publication data“). The publication data includes information supplied by you through the website ‘comment’ function, including your name, email address, website and comment. This publication data may be processed for the purposes of enabling such comment publication on to my website. The legal basis for this processing is my legitimate interests, namely improving the content of the website and communication with website users.
3.4 I may process information contained in or relating to any communication that you send to me by email or website contact forms (“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 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 my legitimate interests, namely the proper administration of my website and communication with website users.
3.5 I may process your personal data that is provided by you in the course of subscribing to the website’s email newsletter service (“service data“). The service data includes your email address. The source of the service data is you. The service data is processed to provide an email newsletter service. The legal basis for this processing is the performance of an email service that you have requested between you and me.
4. Providing your personal data to others
4.1 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 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.
4.2 Aside from the provisions described in 4.1, I will not disclose your personal data to any third-party for any other purpose.
5. Security of your personal data
5.1 I am committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, I have put in place suitable physical, electronic and administrative procedures to safeguard and secure the information the website collects and stores online.
6. International transfers of your personal data
6.1 Certain server storage facilities for the website are hosted by Amazon Web Services and situated in the United States of America. Transfers to this country are protected by appropriate safeguards, namely the EU-US Privacy Shield in which Amazon Web Services participates. Further details can be found here: https://aws.amazon.com/privacy.
6.2 You acknowledge that personal data that you submit for publication through the 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 I may retain your personal data for an indefinite period for the purposes of:
(a) monitoring, improving and protecting the website; and
(b) compliance for potential legal obligations to which I am subject, or in order to protect your vital interests or the vital interests of another person.
8.1 I may update this policy from time to time by publishing a new version on the website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9. Your rights
9.1 I have summarised below the rights that you have under data protection law. Some of the rights are complex, and the details have not been included. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access (subject to an administration fee);
(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.
9.3 You have the right to confirmation as to whether or not I process your personal data and, where I do, access to the personal data, together with certain additional information. Copies will be subject to an administration fee.
9.4 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.
9.5 In some circumstances you have the right to the erasure or the restriction of processing of your personal data without undue delay. Those circumstances include withdrawing consent to receiving website email newsletters.
10. About cookies
10.1 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.
10.2 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.
10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that my website stores about you may be linked to the information stored in and obtained from cookies.
11. Cookies that I use
12. Cookies used by my service providers
13. Managing cookies
13.1 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);
(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
13.2 Blocking all cookies will have a negative impact upon the usability of many websites.
13.3 If you block cookies, you may not be able to use all the features on my website.
14. My details and data protection officer
14.1 The website is owned and operated by Maynard Paton. The data protection officer is Maynard Paton.
14.2 You can contact Maynard Paton by using the contact form here: https://maynardpaton.com/contact/