Disclosure and Privacy Policy

 

Updated Security and Privacy policy

April 2018

 

Introduction

In running our business it is sometimes necessary to collect and process information about you. It can in general be of one or two forms:

  1. When you complete an online form or submit a message to us via our website
  2. Information automatically sent to us by your website browser when you visit our website for instance your IP address – basically where you computer is located or information about which internet browser you are using and so on
  3. Information about how you use our website like the pages you visit and how frequently you visit and how long you stay on the site

The privacy policy sets out details of what information we collect how we use it and how we protect it for you.

 

Our commitment

 

As we are fully committed to safeguarding your personal information we hold on you we will hold it for the minimum time required, that it is used appropriately and that it is held securely.

 

We only ask for minimal data to reduce what we need to safeguard for you so we will only collect your name and email for optin forms for example.

We will strive to be fully compliant with GDPR as possible.

 

Who we are

We are in terms of this website

Lia castelvecchi

Smartpennies.com

Address Ironbrae, Whiterashes AB21 0RB.

Email liasmartpennies@gmail.com

 

Personal Data

Any information that we gather that can identify you directly – name address email.

And we will aim to ask for explicit consent to obtain this information from you.

All though this may not be the only legal basis on which we collect data.

 

Other types of information, for instance, your IP address or geographically location do not generally allow us to directly identify you. Because the European data privacy laws are not completely clear we will cover the use of this data also.

 

Who we share data with

 

We operate on a need to know basis for all data we work with including personal data. The only people/ organisation

 

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 Blackbox Web Design who provide design and/or support services;
  • Our web hosting technology suppliers (currently DigitalOcean and Linode) who provide the physical server infrastructures that our website(s) operate on. We ensure that all servers in use reside physically either in the UK or EU, and that no customer data is transferred to data centres outside the EU.
  • Our cloud storage and technology supplier (currently Amazon Web Services) whose services we use for secure backup storage and email relay services. We utilise AWS data centres within the EU (Ireland) for such purposes.

We have signed Data Privacy Agreements with all of the 3rd party technology suppliers above which detail our respective responsibilities for data security.

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 the section’ on this page. Access is controlled by individual user accounts, where a strong password policy is enforced
  • Dedicated security software: We operate dedicated security scanning and access control software on all of our websites. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.
  • Data encryption: where data is stored in a cloud facility (such as the storage of website backup files), that data is encrypted both ‘in transit’ and ‘at rest’ – meaning that all data is securely obscured both during the process of transfer to the cloud provider, and then added when it is in storage at its final location.
  • This website is also 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 and cloud services. One of the core factors in the selection of such providers is their ability to provide secure systems and processes. We have written Data Processing Agreements with each of our core service providers that sets out the requirements for data security.
  • ICO registration: We are registered with the Information Commissioner’s Office, the UK’s data regulator, ensuring that our data privacy record and reputation is available in the public domain.

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 (which, in the UK, is the Information Commissioner’s Office or ‘ICO’)
  • In most circumstances, you can exercise these rights without paying a fee to us.

Types of data collected

Website contact forms

When you complete one of the contact forms on our website, we will ask you for a number of pieces of personal information, such as your name, email address and other contact details. This is obviously required for us to respond to your request.

If you do not use or submit an online form on the website, no data will be collected in that regard.

More detail

Account logins

For some website functionality, we will need to create for you a user account that allows you to login to the site to ensure that only authorised individuals can access your data and that functionality. Examples include when you make an online purchase via the site, or when you have a role in administering or contributing towards the website content (such as a blog author). The purpose of these user accounts is to protect your personal data behind login security, and to protect the integrity of our site and the servers that run it.

Data collected will generally involve your name and email address (which doubles as username) as a minimum, but may include your postal address if it is required for online purchases.

If you do not register for an online account then no such data will be collected in this regard.

More detail

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.

More detail

Cookies & ‘similar technologies’

We have included cookies, web beacons and similar technologies into one section because they all perform similar functions even if, from a technical perspective, they work slightly differently.

All of these technologies allow us to better understand how users are using our website and other related services. They can also be an essential part of providing certain online functionality. They are all essentially small data files placed on your computer (or other devices) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website.

These technologies are used by most websites as they provide useful insight into how the services are being used, as well as improving speed, performance and security, and enabling us to improve our personalisation of your experience.

Cookies

These are small text files placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:

  • Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
  • Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
  • First-party cookies are set by the site you are visiting.
  • Third-party cookies are set by a third party site separate from the site you are visiting.

There are a number of ways that you can influence how cookies are used on your particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet Explorer, Firefox etc) allow you to set preferences for whether to allow or block website cookies.

They will also provide tools that allow you to remove any cookies that have already been set. Using the ‘Help’ functionality of your browser, or an internet search, will help you to understand how to use these features for your particular browser.

Additionally, we have incorporated specific cookie functionality on our website that allows you to easily indicate when you first visit the site whether or not you are happy for cookies to be set on your device.

Perhaps ironically, for our site to remember your preference for whether to allow cookies or not, it is necessary for us to set cookies for this specific purpose.

When you first visit our site, a Cookie Control box will be displayed allowing you to choose whether to allow cookies or not. Only Essential cookies and those that do not contain/track any personal data will be set when you first visit our site.

By continuing to use our site beyond this cookie information (by scrolling the page, clicking links etc) then you are consenting to the use of cookies, and we will set other non-essential cookies as described in this policy.

You can change your choice at any time by clicking on the persistent cookie icon at the bottom of the screen.

Web beacons

– Small graphic images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites and services that typically work in conjunction with cookies to identify our users and user behaviour.

More detail about our use of cookies

Website Analytics

We use Google Analytics and Piwik Pro to better understand what people look at on our website.

When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) is sent in an anonymous form to Google Analytics (which is controlled by Google) or Piwik Pro (which is hosted on our own servers).

The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from the data.

We ensure that no personally identifiable information is ever contained within the data sent to our analytics providers, and we also perform a process which partially obscures your IP address information.

As analytics information is not personal data, we do not specifically ask for your prior consent.

Facebook

Like the vast majority of commercial websites, we use social media cookies from Facebook on our site. The cookies are placed by Facebook, and we use them to understand the effectiveness of social media campaigns that we operate.

If you are not logged into Facebook when you view our site, then it is not possible for any personal information about your visit to be collected, and therefore we do not specifically ask for your prior consent.

If you are logged into Facebook when you view our site, then Facebook will know when you visit us. We do not have any access to the detail of that personal data, as you have consented to share it with Facebook, not us. We just get to see anonymised data about the numbers of people who have responded to our advertising or other social media activity.

You can learn about Facebook’s privacy policy here.

Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. You can learn about Facebook’s privacy policy here.

There are a number of ways of controlling the ads that you see based upon your activity on Facebook. The following resources may help to understand those choices:

You can always use your browser’s ‘private’ or ‘incognito’ mode to browse websites anonymously.

If you disable marketing cookies on this site, it does not mean that you will not see our ads, it just means that they will not be personalised based on your Facebook activity.

© 2018 Blackbox Web Design | T&Cs | Privacy Policy | ICO Registration: ZA302668

 

All though this may not be the only legal basis on which we collect data.

 

Other types of information for instance your IP address or geographically location do not generally allow us to directly identify you. Because the European data privacy laws are not completely clear we will cover use of this data also.

 

Who we share data with

 

We operate on a need to know basis for all data we work with including personal data. The only people/ organisations granted access are:

  • Employees of smartpennies who provides support or design services
  • Web hosting suppliers – siteground who provide the server infrastructure.
  • We use cloud storage via siteground for data back up.

 

How your data is protected

 

  • Access control as detailed above in who we share data with
  • Security software is in use – limiting login attempts to our wordpress website and blocking malicious attempts to access it and performing website scans as necessary
  • SSL security provided by siteground- data to and from the servers are encrypted both when we use the website and users of our website
  • Third party service providers are limited to essential provision of physical hosting environments and cloud services

 

Access to your Personal data

When you submit an online form or contact us you have the right to:

  • Confirmation about whether any data is being held
  • 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
  • Right to withdraw consent to hold this data at any time even if you have consented
  • Request we recitfy any incomplete or incorrect information held about you
  • Erase any data we hold – right to be forgotten

 

Automatic collection of personal data – internet browsers or via internet cookies or similar

  • Right to object to the legal basis upon which we collect this data and we have an obligation to consider and respond to that objection
  • Right to prevention of further processing of your data while your objection is considered
  • Right to complain to the ICO
  • Without financial penalties in most cases

 

Types of Data

Website contact forms

To allow us to respond to your request we normally require your name, email and contact details – if you do not use or submit an online form on the website no data will be collected.

Account log in

For example if you are purchasing an item from us will involve a name and address and email to allow you to login securely to ensure only authorised individuals can access your data – to protect your personal data behind a login security, protect our site and servers.

If you do not register for an online account then no such data will be collected

 

IP address

This is associated with your device and browser type and version.

These are common place and used to monitor high level server activity and importantly detect and prevent malicious or fraudulent activity on our systems and report any technical issues.

IP data allows us to identify repeats patterns of behaviour such as malicious attempts to gain access to our systems.

They do not in themselves identify you as an individual and it is common for them to be dynamically allocated to your service provider and therefore routinely changed.

We will not and do not use the content of server access logs to attempt to determine an identifiable individual. We do not therefore consider the data held within server logs as under the scope of personal data and therefore do not consent to collect it.

 

Cookies

All these types of technology- cookies web beacons etc allow us to better understand

How users are using our website and other related services. They are an essential part of providing online functionality.

They are small packets of data placed on your computer or device to allow us to tell when you visited a particular page performed an action – click on our website.

They help provide an insight to help improve services such as speed performance security and provide a personalised service.

  • Session cookies- expire at the end of your browser session
  • Persistent cookies- stored in between browser sessions to allow for remembering your preferences or actions along multiple sites
  • 1st party cookies- set by the site you are visiting
  • 3rd party cookies- set by a third party separate from the site you are visiting

Most commercial browsers eg chrome safari internet explorer- allow you to set preferences for whether to allow or block website cookies and tools to remove cookies already set- using the help function on your browser to find out how to do this.

You will of course on your first visit be asked it you happy or not to accept cookies to be set on your device- to allow us to remember your preference for this there is also a cookie set in place!

Only essential cookies and those that do not contain track personal data will be set when you first visit our site. If you continue to use the site beyond this cookie information by scrolling the page clicking links then you are consenting to use cookies and we will set non essential cookies as described.

You can change your choice at any time by clicking on the persistent cookie icon at the bottom of the screen.

Web beacons

Pixel tags or gifs may be included on our sites and work in conjunction with cookies to identify users and their behaviour

 

Website analytics

Google analytics to understand what people are looking at on our website.

Pages you look at how long you spend on the site etc is sent in an anonymous form to google analytics controlled by google.

There is no way to identify such data and as such we do not ask for prior consent.

 

Facebook

We use social media cookies from Facebook on our site and are placed by Facebook and we use them to understand the effectiveness of social media campaigns that we operate. If you are not logged into facebook when you view our site then it is not possible for personal information to be obtained and therefore we do not specifically ask for your prior consent.

Facebook will know if you are logged on when you view our site it is not possible for any personal information to be access by us and as you consented to share data with facebook not us therefore we do not ask for prior consent as the information provided by facebook is anonymised data about numbers of people who have responded to our advertising or other social media activity. Please see Facebooks privacy policy for further information.

 

Pinterest

 

We use social media cookies from Pinterest on our site and are placed by Pinterest and we use them to understand the effectiveness of social media campaigns that we operate. If you are not logged into facebook when you view our site then it is not possible for personal information to be obtained and therefore we do not specifically ask for your prior consent.

Pinterest will know if you are logged on when you view our site it is not possible for any personal information to be access by us and as you consented to share data with Pinterest not us therefore we do not ask for prior consent as the information provided by Pinterest  is anonymised data about numbers of people who have responded to our advertising or other social media activity. Please see Pinterest privacy policy for further information.

 

 

 

Disclosure Policy

Information on Smart Pennies is intended for informational and entertainment purposes only and is not meant to be taken as financial advice. Views expressed on the website are personal opinions and should not be construed as financial advice for your given situation. All attempts are made to provide accurate information it may not be appropriate for your specific circumstances and could be outdated over time. Please contact a financial expert before taking any financial decisions to ensure you have undertaken due diligence.

 

Any claims made on the website nor its members make representation as to the validity, accuracy or completeness of claims or assume liability with regards to financial results based on information provided on the website. Any advertisers, commenters, linked sites are solely responsible for their views and content which may not necessarily represent the views of Smart pennies blog.

Privacy Policy

Smart pennies take your privacy seriously and this policy describes what personal information we collect and how its used.

  • Routine information collection – information is tracked for administration and maintenance purposes and web servers track basic information about their visitors. Includes but not limited to IP addresses, browser details timestamps and referring pages.
  • Cookies and web beacons- if necessary Smart pennies uses cookies to store information about visitors preferences and history in order to serve the visitor better and supply them with custom content. Advertising partners and other third parties may also use cookies, scripts and or web beacons to track visitors to this site in order to display advertisements and other useful information and is done directly by the third parties through their own servers and subjected to their own privacy policies.
  • Controlling your privacy- you can change your browser settings to disable cookies if you are concerned about your privacy concerns. Disabling cookies for all sites can interfere with your site usage so it is recommended to disable just sites you are concerned about. Consult browser support on how to block cookies and other tracking mechanisms.
  • Google advertising- advertisements from google inc. and affiliated companies may be controlled using cookies to allow google to display ads based on your visits to this site and other sites that use google advertising services. Please see google to learn how to opt out of google cookies usage and tracking done by google will also be subject to their privacy policy.
  • Unsubscribe opt out- all visitors to this website can discontinue receiving communication from us by way of emails or newsletters. To discontinue/ unsubscribe please email using the website contact email address. Opting/ unsubscribing of third party websites must be done through third party websites.
  • Links to other websites-  we do not claim nor accept responsibility for any privacy policies, practices, procedures on other websites that are linked to this site. Ensure when you leave this site via any links that you read third party privacy statements of each and every website that collects personally identifiable information. The privacy policy aforementioned only and solely applies to information collected by our website.
  • Security- Physical, procedural and technical security precautions are undertaken to prevent any loss, misuse, unauthorised access, disclosure or modification of the users personal information under our control.
  • Acceptance of terms- using this website means you accept the terms and conditions stipulated in the aforementioned privacy policy agreement. If you do not agree with our terms and conditions then refrain from using our site. If we update or change our terms and conditions and you continue to use our site you are still in agreement to our terms and conditions updates and changes.

 

How to contact us

If you have any questions or concerns regarding this privacy policy agreement please contact us via the following email address.

liasmartpennies@gmail.com

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