fraimed magazine: Privacy & Cookie Policy
In this policy, “we”, “us” and “our” refers to Gerard Brosnan, trading as Flask Publishing, who own and operate this website (www.fraimed.co.uk).
- Introduction
1.1. We are committed to safeguarding the privacy of our website visitors and service users.
1.2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3. When you subscribe to our newsletter and updates, we will take your name and e-mail address. We will use this information purely for the purpose of administering the newsletters, updates and other notifications to interested users who have consented to receive them. We may also use this data in aggregate to provide relevant information to advertisers.
1.4. 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.
2. How we use your personal data
2.1. In this section 2 we have set out:
2.1.1. the general categories of personal data that we may process;
2.1.2. the purposes for which we may process personal data; and
2.1.3. the legal bases of the processing.
2.2. 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. We may use an analytics tracking system for this purpose. 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.
2.3. We do not allow accounts or user dashboards on our website, therefore we will not be processing account data.
2.4. We do not allow comments or user content on our website, therefore we will not be processing such data.
2.5. 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 developing our website to ensure that it meets users’ requirements. The legal bases for this processing are consent and our legitimate interests, namely the proper administration of our website and business.
2.6. We do not offer goods for purchase via our website, nor do we offer paid-for services. Therefore, we will not be processing information relating to transactions.
2.7. We may process information that you provide to us for the purpose of subscribing to our email notifications, updates and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications, updates and/or newsletters. The legal basis for this processing is consent.
2.8. We may process any of your personal data that we have collected and retained 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.
2.9. For the avoidance of doubt, we do not sell, transfer or allow access to your data to any third party agency for marketing and advertising purposes.
2.10. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Providing your personal data to others
3.1. 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.
3.2. Your personal data held in our website database will be stored on a local hard drive maintained at our premises and on the servers of our hosting services providers.
3.3. 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.
- International transfers of your personal data
4.1. In this section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom.
4.2. The hosting facilities for our website will be situated either in the United Kingdom or in countries for which the European Commission has made an “adequacy decision” with respect to the data protection laws of each of those countries, meaning that data transfers to each of those countries will be protected by appropriate safeguards.
- Retaining and deleting personal data
5.1. This section 5 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.
5.2. 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.
5.3. Data will be retained for a maximum period of six (6) years following the date of collection or the date that you unsubscribe from our notifications, whichever shall be the later.
5.4. Notwithstanding clause 5.3 above, 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.
- Your rights
6.1. In this section 6, we have listed the rights that you have under data protection law.
6.2. Your principal rights under data protection law are:
6.2.1. the right to access – you can ask for copies of your personal data;
6.2.2. the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
6.2.3. the right to erasure – you can ask us to erase your personal data;
6.2.4. the right to restrict processing – you can ask use to restrict the processing of your personal data;
6.2.5. the right to object to processing – you can object to the processing of your personal data;
6.2.6. the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
6.2.7. the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
6.2.8. 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.
6.3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by contacting the Information Commissioner’s Office.
6.4. 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.
- About cookies
7.1. 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.
7.2. 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.
7.3. Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
We use cookies for the following purposes:
8.1. advertising – we use cookies to help us to display advertisements that will be relevant to you;
8.2. analysis – we use cookies to help us to analyse the use and performance of our website and services; and,
8.3. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
- Cookies used by our service providers
9.1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
9.2. 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. We also use Mail Chimp for e-mail marketing.
- Managing cookies
10.1 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.
10.2. Blocking all cookies will have a negative impact upon the usability of many websites.
10.3. If you block cookies, you will not be able to use all the features on our website.
10.4. Using Ad Block filters, or other similar software and features, may affect the usability of our website and your ability to use features on our website.
- Links to other websites
This website may contain links to other websites of interest. Once you have used
these links to leave our site we cannot be responsible for the protection and privacy
of any information which you provide whilst visiting such sites and such sites are not
governed by this privacy statement. You should exercise caution and look at the
privacy statement applicable to the website in question.
- Embedded content from other websites
12.1. Pages on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
12.2. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
- Amendments
13.1. We may update this Policy from time to time by publishing a new version on our website.
13.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
- Contacting Us
You can contact us:
14.1. using our website contact form;
14.2. by email, using the email address published on our website.
- Data protection officer
Our data protection officer can be contacted by e-mail to us at legal@fraimed.co.uk
Current as at 18th January 2020.