Privacy

INTRODUCTION

Welcome to the privacy notice related to The STP Literary Service (“STP”/”STP Editing”).

The STP Literary Service and David Brookes respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how I look after your personal data when you visit my website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can easily navigate the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice, and contact me at any time if you have any questions.

Table of Contents – Privacy and Data Protection:

  1. Important information and who I am
  2. That data I collect about you
  3. How your personal data is collected
  4. How I use your personal data
  5. Disclosures of your personal data
  6. International transfers of your data
  7. Data Security
  8. Data Retention
  9. Your legal rights
  10. Glossary


1. IMPORTANT INFORMATION AND WHO I AM

     1.1 PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how The STP Literary Service collects and processes your personal data through your use of this website or via email, including any data you may provide through this website when you email STP, or its operator David Brookes, or send a message to the same via this website’s Contact page.

This website is not intended for children and I do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice I may provide on specific occasions when I am collecting or processing personal data about you, so that you are fully aware of how and why I am using your data. This privacy notice supplements the other notices and is not intended to override them. Please also refer to my policy on cookies.

     1.2 CONTROLLER

The STP Literary Service is the controller and responsible for your personal data (collectively referred to as “The STP Literary Service”, “STP”, “STPEditing”, “I”, “me” or “my”, “the company” in this privacy notice).

David Brookes, the owner of The STP Literary Service, operates as a sole trader (I have no boss, stakeholders or employees), and I am by default the data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

     1.3 CONTACT DETAILS

My details are:

Full name of legal entity: The STP Literary Service

Name or title of data privacy manager: David Brookes

Email address: davidbrookesuk@gmail.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact me in the first instance.

     1.4 CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM ME OF CHANGES

This version was last updated on 24 May 2018 and historic versions can be obtained by contacting me. This privacy policy may be updated periodically without prior notice to you to reflect changes in my information practices. I will post a notice on the website or notify you by emails of any significant changes to this privacy policy and indicate in the notice when it was most recently updated.

It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.

     1.5 THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. For example, my blog posts may link to articles across the web, there are social media links to pages like Twitter, and my Support page links to PayPal. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit.

  1. THE DATA I COLLECT ABOUT YOU

2.1 TYPES OF DATA

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

I may collect, use, store and transfer different kinds of personal data about you. I do not keep any kind of database to store this sort of information, but it might be included in the emails or files you send to me. I have grouped the kinds of data together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account details, payment card details, and details of other payment services such as PayPal.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from me – i.e., previous editing or ghostwriting projects that you have hired me for.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This information is not collected deliberately by the company, but via automated processes such as cookies, which you can read about on the Cookies page.
  • Profile Data includes any username you may have used to leave a comment on the website, which requires you to be logged into your WordPress, Google+ or other account in order to do so. This information is not collected deliberately by the company, but via automated processes such as cookies, which you can read about on the Cookies page.
  • Usage Data includes information about how you use my website, products and services. This information is not collected deliberately by the company, but via automated processes such as cookies, which you can read about on the Cookies page.

I may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy notice. Please note that I do not currently collect this kind of data, but should I use an analytical tool on my website to see which of my posts is most popular, for example, then this sort of data may be used by the software automatically.

I do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do I collect any information about criminal convictions and offences.

     2.2 IF YOU FAIL TO PROVIDE PERSONAL DATA

Where I need to collect personal data by law, or under the terms of a contract I have with you and you fail to provide that data when requested, I may not be able to perform the work that I have agreed to undertake for you. In this case, I may have to cancel the service you have with me but I will notify you if this is the case at the time.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

I use different methods to collect data from and about you, including through:

  • Direct interactions. You may give me your identity, contact and financial data by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:
    – apply for any of my services, such as proofreading, editing or ghostwriting;
    – agree to my using a sample of the completed work; or
    – give me some feedback or leave a testimonial.
  • Automated technologies or interactions. As you interact with my website, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. Please see the Cookies page for further details.
  • Third parties or publicly available sources. I may receive personal data about you from various third parties, including Technical Data from parties such as analytics providers like Google, based outside the EU.
  1. HOW I USE YOUR PERSONAL DATA

4.1 CIRCUMSTANCES

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

  • Where I need to perform the work that you have hired me for.
  • Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where I need to comply with a legal or regulatory obligation, such as taxes.

Generally I do not rely on consent as a legal basis for processing your personal data. By hiring me for your literary needs you will have already provided me with the information I need to do the job and agreed to this privacy policy.

     4.2 PURPOSES FOR WHICH I WILL USE YOUR PERSONAL DATA

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to me

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for my legitimate interests (to recover debts due to me)

 

To manage my relationship with you which will include:

(a) Notifying you about changes to my terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for my legitimate interests (to keep my records updated and to study how customers use my products/services)

 

To administer and protect my business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising I serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for my legitimate interests (to study how customers use my products/services, to develop them, to grow my business and to inform my marketing strategy)

 

To use data analytics to improve my website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for my legitimate interests (to define types of customers for my products and services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

Necessary for my legitimate interests (to develop my products/services and grow my business)

 

 

     4.3 MARKETING  / PROMOTIONS

I never use your information for marketing. Hopefully I will do a good job and you will come back to hire me again later – I don’t believe in spamming my clients with emails to get more work. I don’t keep information on marketing/circular preferences, because I don’t ever contact you for anything except the project that I am currently working on for you. Once you have confirmed that you’re happy with the work and the fee has been settled, you won’t be contacted by me again unless you contact me first, except immediately afterwards when I may ask if you would like to leave a testimonial or if I can (anonymously) use the work we did together as a sample for my portfolio

     4.4 COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. More information about the cookies I use is on the main Cookies page.

     4.5 CHANGE OF PURPOSE

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me.

If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.

Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. DISCLOSURES OF YOUR PERSONAL DATA

I have never, and will never, share your personal data for any reason.

I am required to keep a record of my income for tax purposes. I list an abbreviated version of your name or your company’s name (if you hired me via Freelancer.com, this will be your Freelancer username), the date on which you hired me, the type of work you hired me to do (i.e. “proofreading” or “ghostwriting”), the method by which I was hired (i.e. via my website/email address, or via a freelancing site like Freelancer.com/Upwork), the word count of the file, my rate and the fee that I charged. You can’t be personally identified by this record, and it’s never shared with anyone except for UK tax officials at the HMRC when I have to make my annual tax declaration.

  1. INTERNATIONAL TRANSFERS

I do not transfer your personal data outside the European Economic Area (EEA), except when I am required to send your files by email. For example, Google’s Gmail servers are based outside of the EU.

Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Your files will be encrypted with a password, or zipped into a .zip file that is encrypted. The password will be sent to you in a separate message via email or another media such as text message.
  • Your files will be uploaded to a secure server such as Google Drive or Dropbox, to which only you and I have access.

Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the EEA.

  1. DATA SECURITY

I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. I am a sole trader, which means that I have no employees, agents, contractors or other third parties who have a reason to access that information. Should a third party need access to that information for the express purposes of completing the work you hired me for, they will only process your personal data on my instructions and they are subject to a duty of confidentiality and you will be informed of their involvement.

I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so.

  1. DATA RETENTION

     8.1 HOW LONG I WILL USE YOUR PERSONAL DATA FOR

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

In most cases, I will keep your files, instructions and invoices on my hard disc for a maximum of 1 year. This allows me to refer to previous projects should you hire me a second or third time, etc., for the purposes of consistency. If you ever wish for me to delete your data immediately after a project, please ask and I will do so and confirm that your files have been deleted from my hard disc (see “Request erasure”).

By law I have to keep basic information about my customers for up to seven years after they cease being customers for tax purposes (See “Disclosures of your personal data”).

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.

Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.

Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If you request erasure of your data before I have finished processing it (i.e., before I finish the job you hired me for), then the project will by necessity be concluded, work will cease, and you will be billed for the percentage of work that has been completed up until that point. In that case, I will be required to retain your contact details until payment has been made, at which point I will delete them.

Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data’s accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.

Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact me.

     9.1 NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

     9.2 WHAT I MAY NEED FROM YOU

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Before I can begin the work that you intend to hire me for, I will refer you to this privacy policy and ask for your explicit acknowledgement of this policy and agreement for me to go ahead. I may also contact you to ask you for further information in relation to your request to speed up my response.

9.3 TIME LIMIT TO RESPOND

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

  1. GLOSSARY

10.1 LAWFUL BASIS

Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.

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