v1.1.0—last updated 2019-05-19
In order for us to operate our business and provide our services to You, it is sometimes necessary for us to collect or process information about You. In general terms, this information will take one or more of the following forms:
- Information that you provide to us directly, such as in the situation where you complete an online form or send us a message via our website;
- Information that is automatically sent to us by Your computer’s internet browser when you visit our website, such as your computer’s technical address (or “IP address”) or information about which particular internet browser you are using and so on;
- Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.
Our Commitment to Data Privacy
We are fully committed to maintaining the privacy of any information (“personal data”) that you provide to us. Furthermore, we commit to ensuring that such data is held securely, used appropriately and only retained for as long as is necessary.
Our systems and services are designed with privacy in mind, and we operate on a “data minimisation” principle wherever possible – that is to say that we will only ever ask you for the minimum amount of information required to provide our services efficiently; we have no desire to retain (and therefore maintain) any more information than is necessary.
We aspire to comply to the fullest extent possible with applicable data protection regulations, in particular the European Union’s General Data Protection Regulation (“GDPR”) and ePrivacy Directive, where applicable.
Who We Are
In terms of your use of this website, We, Ilona Demidenko, act in the capacity of Data Controller, and should you have any questions or concerns about the data we hold about you, we can be contacted using the information below:
- Data Controller: Ilona Demidenko
Email correspondence: firstname.lastname@example.org
Definition of Personal Data
When we refer to “personal data” we mean any information that allows us to identify you personally. Obvious examples include your name, email address, postal address etc.
We will always seek to gain your explicit consent to providing this information before we collect it from you, although this may not be the only legal basis on which we collect the data.
Other types of information, such as your computer’s “IP” address or broad geographical location do not, generally, allow us to identify you directly.
However, because in their current form, European data privacy regulations are somewhat vague in this regard, we will cover the use of such data here also.
Who We Share Data With
We operate on a strict “need to know” basis for all data that we work with, and that is particularly true for any personal data. The only people/organisations that are granted access to personal data are:
- Employees of Ilona Demidenko who provide content-creation, design, marketing, sales, software development, and/or support services;
- Our web hosting technology suppliers (currently GitHub Pages) who provide the static website server that we operate on. Only the technical address of your computer (“IP address”) is being transfered by your browser to these website servers.
For cross-border data transfers from the European Union (EU) and the European Economic Area (EEA), GitHub adheres to the Privacy Shield Framework.
- Our email marketing automation platform MailChimp who provide data processing services. MailChimp is an US based company which means that your data is transferred to servers outside the European Union.
MailChimp has certified to the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework, so your personal data is transferred lawfully outside of the EU to MailChimp in the U.S.
How Your Data is Protected
We take the security of all personal data very seriously, and that data is protected in a number of ways:
Access control: access to personal data is strictly limited in line with our policy detailed in the “who we share data with section” on this page. Access is controlled by individual user accounts, where a strong password policy is enforced.
Data encryption: This website is secured with SSL encryption, which means that all traffic to and from our servers is encrypted. This applies to our own administrative access to the website as well as that of users of our services.
Additionally, we ensure that our own dedicated secure Virtual Private Network (VPN) is used when we access the site from anywhere on a public wifi network.
- Selection of third party service providers: we use a very limited number of third party service providers, but some are essential for the provision of physical hosting environments, cloud services, and email services. One of the core factors in the selection of such providers is their ability to provide secure systems and processes.
Access to Your Personal Data
In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:
- You have the right to obtain from us confirmation about whether any such data is being held;
- You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
- Even if you have consented to Us processing your personal data, you have the right to withdraw that permission at any time;
- You have the right to require us to rectify any incomplete or incorrect information held about you;
- You have the right to require us to erase the data held about you (the “right to be forgotten”);
In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies):
- You have the right to object to the legal basis upon which we are collecting this data, and We have an obligation to consider and respond to that objection;
- You have the right to request the prevention of further processing of your data while your objection is considered;
- You have the right to make a complaint to the relevant data protection authority (In Berlin/Germany: Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI));
- In most circumstances, you can exercise these rights without paying a fee to us.
Types of Data Collected
Customer data includes data relating to any purchases of goods and/or services such as your name, email address, contact details and purchase details.
- performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Types of Processing
- to supply the goods and/or services you have purchased and to keep records of such transactions.
This includes data about your preferences in receiving marketing from us, and your communication preferences.
Types of Processing
- to enable you to partake in our promotions such as competitions, prize draws and free giveaways,
- to deliver relevant website content and advertisements to you, and
- to measure or understand the effectiveness of this advertising.
- our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
Technical Data (Such as “IP” Address)
When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical “IP” address that is associated with your device and the browser type and version that you are using.
Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems.
This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behaviour (such as repeated malicious attempts to access a system).
IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.
Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of “personal data”, and accordingly we do not seek your consent to collect it.
In the event that such anonymous data is considered to fall within the scope of the applicable data protection regulations, the legal basis for processing such data is:
Our Legitimate interest (GDPR Art 6(1)(f)): The integrity, security and performance of our systems and infrastructure is a vital part of the services that we offer. We consider that it is in our legitimate interest to maintain and protect our systems to this end.
Types of Processing
- We will store the information you provide to us in our website server logs
- For the purpose of maintaining the integrity of our systems, we may also store this data in infrastructure backups
- We will NOT use this data to attempt to identify an individual person
Our legal basis of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at email@example.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten years after they stop being customers.
In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Cookies & “Similar Technologies”
We are not collecting any cookies or use any similar technologies.
We are not using any website analytics technology.
What Information We Do Not Collect
We do not collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information.
If you’re a child under the age of 13, you may not use this website or have an account for any of our products. We do not knowingly collect information from or direct any of our content specifically to children under 13. If we learn or have reason to suspect that you are a user who is under the age of 13, we will unfortunately have to close your account and delete any of your data.
Other countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not use our website or our products without obtaining your parents’ or legal guardians’ consent.