Privacy Policy

Below is my official privacy policy in legal terms. But before that, I thought I'd summarise my approach to the privacy of your data in simple terms.

In short, I take the privacy of your data very seriously. I will never sell or otherwise pass on any of your personal data to anyone else.

My website will place cookies in your web browser, to enable me to better understand who is visiting my site and how you use it, as well as to tailor the content better for your needs. Your viewing my website means you're happy with me placing those cookies.

If you send me a message via my contact form your name and email address will be stored in my email program and I'll use it to reply to you. Filling in my contact form does not place your email on an email list database. 

If you opt in to any of my free resources, your first name and email address will be stored in my email marketing software—Moosend. If you opt in, I'll send you regular helpful emails that you can unsubscribe from instantly with one click at any time. I won't pass your email address onto anyone else.

Feel free to ask me for a copy of any personal data I've collected about you, or if you'd like me to delete that data. 

If you have any questions about how I capture and store your personal data, don't hesitate to ask.

Ok... on with the legal stuff.

Privacy Policy of stephengordon.org

This Website collects some Personal Data from its Users.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller 

7 Parklands, Larne, Co. Antrim, Northern Ireland, BT40 1WW

Owner contact email: stephen@stephengordon.org

Types of Data collected 

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Usage Data; Tracker; email address; first name; Data communicated in order to use the Service. 

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Displaying content from external platforms, Tag Management, Platform services and hosting, Remarketing and behavioral targeting, Advertising, Analytics, Managing contacts and sending messages, Contacting the User and Information collection. 

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. 
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Facebook Lookalike Audience 

Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of this Website or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.

Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Facebook Ads conversion tracking (Facebook pixel) 

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy

Google Analytics

We use Google Analytics to provide visitor behaviour tracking and analytics.

You can read Google's privacy policy here.

YouTube Analytics and Reporting API (Google Ireland Limited)

YouTube Analytics and Reporting API is a video content analytics service provided by Google Ireland Limited.

Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.

Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

Personal Data processed: Data communicated in order to use the Service.

Place of processing: Ireland – Privacy Policy – Opt out

Contacting the User

Mailing list or newsletter (this Website)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.

Personal Data processed: email address; first name.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts 

Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that allows this Website to incorporate content of this kind on its pages.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy

Wistia widget (Wistia, Inc.)

Wistia is a video content visualization service provided by Wistia, Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy

YouTube IFrame Player (Google Ireland Limited)

YouTube IFrame Player is a video content visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.

Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.

Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

Personal Data processed: Data communicated in order to use the Service.

Place of processing: Ireland – Privacy Policy – Opt out

Information collection

Fluent Forms

We use Fluent Forms to power our opt-in pop-up boxes to collect a first name and email address.

Fluent Forms pass the form submission directly to Moosend, our email marketing provider (see elsewhere in this page for Moosend's privacy policy). Moosend also stores a cookie in your browser to track your visit, to allow us to serve more relevant offers to you. Fluent Forms does not store your data.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Moosend

Moosend is an email address management and message sending service provided by Moosend.

Personal Data processed: email address; first name; Tracker; Usage Data.

Place of processing: European Union – Privacy Policy

Platform services and hosting

These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. 
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

WordPress and Cloudways

WordPress is a platform hosted by Cloudways that allows the Owner to build, run and host this Website. WordPress is highly customizable and can host websites from simple blogs to complex e-commerce platforms.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy

Remarketing and behavioral targeting

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Facebook Custom Audience 

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, that connects the activity of this Website with the Facebook advertising network.

Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: email address; Tracker.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out

Facebook Remarketing 

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Website is accessed from, that connects the activity of this Website with the Facebook advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager 

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. 

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

This Website uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. 

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Website, if not stated otherwise within this document.

Latest update: 11th April 2021

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