2. How WriteOnline uses your personal data
2.1 WriteOnline may process data about your use of the 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 WriteOnline’s analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent in order to legitimately monitor and improve the website and services.
2.2 WriteOnline may process your website user account data (“account data“). The account data may include your name and email address. You are the source of the account data. The account data may be processed for the purposes of operating the website, providing services, ensuring the security of the website and services, maintaining back-ups of databases and communicating with you. The legal basis for this processing is consent in order to legitimately and properly administer the website and WriteOnline business interests which might include at your request entering into a contract with you.
2.3 WriteOnline may process information that you post for publication on the website or through the platform’s other services] (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering the website and services. The legal basis for this processing is consent in the legitimate interests of properly administering the website and business.
2.4 WriteOnline may process information contained in any enquiry you submit regarding courses 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 in the legitimate interests of properly administrating the website and business.
2.5 WriteOnline may process information that you provide for the purpose of subscribing to 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 in the legitimate interests, namely, communications with our website visitors and service users, or in the performance of a contract between you and WriteOnline entered into at your request.
2.6 WriteOnline may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is WriteOnline’s legitimate interests, namely the protection and assertion of its legal rights, your legal rights and the legal rights of others.
2.7 WriteOnline may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is WriteOnline’s legitimate interests, namely the proper protection of the business against risks.
2.8 In addition to the specific purposes for which WriteOnline may process your personal data set out in this Section 3, WriteOnline may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which WriteOnline is subject, or in order to protect your vital interests or the vital interests of another natural person.
2.9 Please do not supply any other person’s personal data, unless asked to do so.
2.10 WriteOnline does not direct the website administrators to collect, nor is the personal information from children under 16 years of age, knowingly collected.
3 Providing your personal data to others
3.1 WriteOnline may disclose your personal data to its insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 Your personal data held in the WriteOnline website database will be stored on the servers of WriteOnline’s hosting services providers which information will be disclosed to you on written request.
3.3 In addition to the specific disclosures of personal data set out in this section, WriteOnline may disclose your personal data in compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person. WriteOnline may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.4 You are requested to please be careful about disclosing personal information during your interactions on the chat-room forums during the course.
4 International transfers of your personal data
4.1 The hosting facilities for the WriteOnline website are situated in the United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to these countries will be protected by appropriate safeguards, namely, the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules/eu-data-protection-rules_en
4.3 You acknowledge that personal data that you submit for publication through WriteOnline’s website or services may be available, via the internet, around the world. WriteOnline cannot prevent the use (or misuse) of such personal data by others. However, WriteOnline is committed to protecting the security of your information. What is regarded as appropriate physical, electronic and managerial procedures to safeguard and secure your information and to prevent unauthorised access, maintain accuracy, and ensure appropriate use of your information are in place. The accuracy, safety, and security of your information also depends on you. Where you have a self-generated password for access to the short course, you are responsible for keeping this password confidential. Do not share your password with anyone. As stipulated above, although WriteOnline does its best to protect your information, the transmission of information via the internet is not completely secure and the WriteOnline security measures cannot be guaranteed. WriteOnline is not responsible for any unauthorised access to or acquisition of your information.
5 Retaining and deleting personal data
5.1 Personal data that WritingOnlies processes for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.2 WriteOnline will retain your personal data as follows:
(i) usage and analytic data will be retained for a minimum period of 0 days following the date of collection, and for a maximum period of 48 months following that date;
(ii) account data will be retained for a minimum period of 0 days following the date of closure of the relevant account, and for a maximum period of 31 daysfollowing that date;
(iii) publication data will be retained for a minimum period of 0 days following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period of 48 months following that date;
(iv) enquiry data will be retained for a minimum period of 14 daysfollowing the date of the enquiry, and for a maximum period of 12 months following that date;
(vi) Notwithstanding the other provisions of this Section 6, WriteOnline may retain your personal data where such retention is necessary for compliance with a legal obligation or to protect your vital interests or the vital interests of another natural person.
6 Your rights
6.1 Your principal rights under data protection law are:
(i) the right to access – you can ask for copies of your personal data;
(ii) the right to rectification – you can ask to rectify inaccurate personal data and to complete incomplete personal data;
(iii) the right to erasure – you can ask to have your personal data erased;
(iv) the right to restrict processing – you can request that use be restricted to the processing of your personal data;
(v) the right to object to processing – you can object to the processing of your personal data;
(vi) the right to data portability – you can ask that your personal data be transferred to another organisation or to you;
(vii) the right to withdraw consent – to the extent that the legal basis of WriteOnline’s processing of your personal data is consent, you can withdraw that consent.
6.2 These rights are subject to certain limitations and exceptions.
6.3 You may exercise any of your rights in relation to your personal data by written notice to WriteOnline, using the email address on the website.
7 About cookies
7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a webserver 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.
7.2 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 will expire at the end of the user session, when the web browser is closed.
7.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
8 Cookies that we use
(i) authentication and status – to identify you when you visit the website and as you navigate the website, and to determine if you are logged into the website;
(ii) personalisation – to store information about your preferences and to personalise the website for you;
(iii) security – as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect the website and services generally;
(iv) analysis – to analyse the use and performance of the website and services; and
9 Cookies used by our service providers
10 Managing cookies
10.1 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.
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on the WriteOnline website.
11.1 WriteOnline may update this policy from time to time by publishing a new version on the website.
11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
12 Our details
12.1 This website is owned and operated by WriteOnline.
12.2 WriteOnline can be reached by using the website contract form or by email using the email address published on the website.
Credit This document was created using a template from SEQ Legal