Privacy Policy
Section 1: Introduction
1.1
It is Jane Austen Variations’ policy to respect your privacy regarding any information we may collect from you or which you may provide to us, in the circumstances set out below. Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose, safeguard and otherwise make use of your personally identifiable information (“Personal Data”).
1.2
We will only collect and use your Personal Data where:
- we have lawful grounds to do so, including to comply with our legal obligations;
- we are performing a contract with you for our services; and
- we have legitimate interests in using your Personal Data and your interests and fundamental rights do not override those interests.
1.3
For the purposes of the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”), we, Jane Austen Variations, are the “data controller”. If you have any questions about this policy or about how we use your Personal Data, please contact us via our contact details at the end of this policy. This policy is effective as of May 25, 2018. We review our privacy practices on an ongoing basis, and as such we may change this privacy policy from time to time. Please check this page frequently to ensure you are familiar with its current content.
Section 2: Credit
This document was created using a template from SEQ Legal (https://seqlegal.com).
Section 3: Data we collect via JaneAustenVariations.com
3.1 Personal Data that you provide to us
We only collect Personal Data where you choose to interact with us on the Website in the following ways:
- when you sign up to receive website updates.
- At that time you provide name and email address
- when you complete comments or the contact form
- at that time you provide name, email address, and any data you enter into the text box in comments or on the contact form.
3.2
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.3 Data that we collect automatically
We automatically collect certain information when you visit our Website – such as the type of browser and operating system you are using, and the domain name of your Internet service provider. We do not link this information with any Personal Data. We may also collect data automatically through our use of cookies on the Website. Please see our cookie policy [Sections 9-12] to find out about the types of cookies we set and why, and how you can adjust your settings to disable cookies.
Section 4: Sharing your personal data
Article 13(1)(e) of the GDPR requires that where personal data are collected from the data subject, the data controller must provide the data subject with information about “the recipients or categories of recipients of the personal data”.
Equivalent rules for data collected from someone other than the data subject are in Article 14(1)(e).
4.1
We take your privacy seriously and will not share your Personal Data with others, except as permitted by applicable law or as set out below:
We may disclose your personal data to any member of our group of authors (this means members of the Jane Austen Variations blog group) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of authors can be found at JaneAustenVariations.com.
We share Personal Data as necessary with third parties who provide services or functions on our behalf and who require the information to provide those specific services to us. These third parties may include social media advertising platforms such as Facebook and Google Adwords for the purpose of custom audience generation and the development of targeting criteria for other audiences. Please note that we have appropriate data privacy safeguards in place with third parties with whom we share Personal Data as described above and who are providing services or functions on our behalf.
4.2
In addition to the specific disclosures of personal data set out in this Section 4, 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 defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.]
4.3
You acknowledge that personal data that you submit for publication through JaneAustenVariations.com may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Section 5: Retaining and deleting personal data
Article 5(1)(e) of the GDPR sets out the storage limitation, one of the fundamental rules of the regime:
“Personal data shall be: … kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject … “.
5.1
We will use and store your Personal Data only for as long as necessary, bearing in mind the uses of your Personal Data as described in this privacy policy and otherwise as communicated to you. We review the Personal Data we hold at regular intervals and delete permanently or anonymize any Personal Data which is no longer necessary.
5.2
Notwithstanding the other provisions of this Section 6, 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.
Section 6: How we use your personal data
Article 13(1) of the GDPR provides that:
“(1) Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information: … (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing; (d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party”.
Article 6(1)(f) of the GDPR provides that:
“(1) Processing shall be lawful only if and to the extent that at least one of the following applies: … (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”
6.1
Article 14 of the GDPR, which applies where personal information is not obtained from the data subject, provides that information about “the categories of personal data concerned” must be supplied to data subjects.
Article 13 of the GDPR, which applies where personal information is obtained from the data subject, does not include an equivalent provision.
Nonetheless, we have included references to general categories of data in this document, because this facilitates the identification of particular purposes of processing and the legal bases of processing – information which does need to be provided under Article 13.
6.2
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. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing our legitimate interests, namely monitoring and improving our website and services.
6.3
We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
6.4
We may process information that you post for publication (comments) on our website (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
6.5
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 offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
6.6
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
6.7
We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our 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 our legitimate interests, namely the proper administration of our website and business and communications with users.
6.8
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Section 7: Children
This Website and our services are aimed at adults, and we do not knowingly collect any Personal Data relating to children aged under 15 years old. If you are under the age of 15, please do not provide us with any of your Personal Data, including your email address.
Section 8: Access to and control over your Personal Data
You have legal rights under applicable law in relation to your Personal Data. You can ask the following questions, or take the following actions, at any time by contacting us via email admin@austenvariations.com
- see what Personal Data we hold about you (if any), including why we are holding it and who it could be disclosed to;
- ask us to change/correct your Personal Data;
- ask us to delete your Personal Data;
- object to the processing of your Personal Data;
- ask us to restrict the processing of your Personal Data;
- withdraw any consents you have given us to the processing of your Personal Data; and
- express any concerns you have about third parties’ use of your Personal Data.
The right to access is set out in Article 15 of the GDPR.
Section 9: About cookies
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.
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.
Section 10: Cookies that we use
When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Section 11: Cookies used by our service providers
11.1
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; Facebook, Twitter, LinkedIn, Google Plus, Pinterest, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
11.2
We use Google Analytics to analyze the use of our website. Google Analytics is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. gathers information about website use by means of cookies. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
Section 12: Managing cookies
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);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(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
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites.
If you block cookies, you will not be able to use all the features on our website
Section 13: Our details
You can contact us: using our website contact form; or by email, admin@austenvariations.com
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