1. Introduction
1.1 We are committed to safeguarding the privacy of InsiderScotland (https://www.insiderscotland.com) website visitors.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of InsiderScotland (https://www.insiderscotland.com) website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website (https://www.insiderscotland.com).
1.4 In this policy, “we”, “us” and “our” refer to the InsiderScotland (https://www.insiderscotland.com) data controller Jennifer McKelvie.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website (https://www.insiderscotland.com) (“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 Google Analytics (https://analytics.google.com). This usage data may be processed for the purposes of analysing the use of the InsiderScotland (https://www.insiderscotland.com) website. The legal basis for this processing is consent.
3.3 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 include your name and email address. We collect notification data using the MailChimp email marketing service (https://mailchimp.com). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters and communicating with you. The legal basis for this processing is consent.
3.4 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. 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.
4. Providing your personal data to others
4.1 We may disclose your name and email address to our competition partners as identified in individual competitions hosted through our website (https://www.insiderscotland.com) insofar as reasonably necessary for you to receive your prize, or where you have specifically given consent for a named partner to send you email notifications and/or newsletters. Each such third party will act as a data controller in relation to the notification data that we supply to it; and upon contacting you, each such third party will make available a copy of its own privacy policy, which will govern that third party’s use of your personal data.
5. 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 We will retain your personal data as follows:
(a) usage data will be retained in accordance with Google Analytics privacy policy https://www.google.com/policies/privacy/.
(b) notification data will be retained until you unsubscribe from our email marketing list, which we manage via MailChimp as specified in section 3.3.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of correspondence data will be determined based on the content of the correspondence.
5.5 Notwithstanding the other provisions of this Section 5, 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.
6. Children’s privacy
6.1 This website is directed to adults; it is not directed to children under the age of 16. We operate our site in compliance with the Children’s Online Privacy Protection Rule (COPPA) in the United States and the General Data Protection Regulation (GDPR) In the European Union. As such we do not knowingly collect or use personal information from anyone under 16 years of age.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport plus a copy of a recent utility bill showing your current address OR a copy of a recent utility bill and a copy of a recent bank or credit card statement).
8.2 We may withhold personal information that you request to the extent permitted by law.
8.3 You may instruct us at any time not to process your personal information for marketing purposes.
8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
9. About cookies
9.1 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.
9.2 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.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) navigation – we use cookies when you visit our website and as you navigate our website (cookies used for this purpose are: navigation cookies).
11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. 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/ (cookies used for this purpose are: analytical cookies).
11.3 We publish Google AdSense personalized advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies (cookies used for this purpose are: advertising cookies). You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: https://optout.networkadvertising.org/?c=1. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
11.4 We are a participant in the Amazon EU Associates Programme, an affiliate advertising programme designed to provide a means for sites to earn advertising fees by advertising and linking to Amazon.co.uk (cookies used for this purpose are: advertising cookies).
By using the sites you are agreeing to the use of cookies as described.
12. Our details
12.1 This website is owned and operated by Robin McKelvie and Jennifer McKelvie.
12.2 You can contact us:
(a) by email, using the email address published on the ‘About Us’ page of our website.
13. Agreeing to Terms
If you do not agree to InsiderScotland’s Privacy Policy please do not use this site or any services offered by this site.
Your use of this site indicates acceptance of this privacy policy
Last Updated: May 2018
