Definitions and interpretation
|Data||collectively all information that you submit to PA Answer Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;|
|Cookies||a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);|
|Data Protection Laws||any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;|
|GDPR||the General Data Protection Regulation (EU) 2016/679;|
|PA Answer Limited, or us||PA Answer Limited of 46a St Marys Street, Ely, CB74EY;|
|UK and EU Cookie Law||the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;|
|User or you||any third party that accesses the Website and is not either (i) employed by PA Answer Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to PA Answer Limited and accessing the Website in connection with the provision of such services; and|
|Website||the website that you are currently using, www.thewriteimpression.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.|
context requires a different interpretation:
- the singular includes the plural and vice versa;
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- reference to any statutory provision includes any modification or amendment of it;
- For purposes of the applicable Data Protection Laws, PA Answer Limited is the “data controller”. This means that PA Answer Limited determines the purposes for which, and the manner in which, your Data is processed.
- We may collect the following Data,
which includes personal Data, from you:
- job title;
- contact Information such as email addresses and telephone numbers;
- demographic information such as postcode, preferences and interests;
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
How we collect Data
- We collect Data in the following
- data is given to us by you; and
- data is collected automatically.
Data that is given to us by you
- PA Answer Limited will collect your
Data in a number of ways, for example:
- when you contact us through the Website, by telephone, post, e-mail or through any other means;
- when you register with us and set up an account to receive our products/services;
- when you enter a competition or promotion through a social media channel;
- when you elect to receive marketing communications from us;
- when you use our services;
Data that is collected automatically
- To the extent that you access the
Website, we will collect your Data automatically, for example:
- we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data
- Any or all of the above Data may be
required by us from time to time in order to provide you with the best possible
service and experience when using our Website. Specifically, Data may be used
by us for the following reasons:
- internal record keeping;
- improvement of our products / services;
- transmission by email of marketing materials that may be of interest to you;
- We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
- For the delivery of direct marketing to you via
e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
- When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Who we share Data with
- We may share your Data with the following groups of
people for the following reasons:
- our employees, agents and/or professional advisors – To deliver services, create and update research and monitor project success;
- third party service providers who provide services to us which require the processing of personal data – Through our media database provider (Agility), Business Wire and Campaign Monitor solely for the purpose of managing the client account under the agreed terms;
Keeping Data secure
- We will use technical and organisational measures
to safeguard your Data, for example:
- access to your account is controlled by a password and a user name that is unique to you.
- we store your Data on secure servers.
- Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: firstname.lastname@example.org.
- If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
- Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
- You have the following rights in relation to your
- Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
- Right to erase – the right to request that we delete or remove your Data from our systems.
- Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
- Right to data portability – the right to request that we move, copy or transfer your Data.
- Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
- To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: email@example.com.
- If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
- It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
- All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
- Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling PA Answer Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
- This Website may place the following Cookies:
|Type of Cookie||Purpose|
|Strictly necessary cookies||These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.|
|Analytical/performance cookies||They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.|
|Functionality cookies||These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).|
- You can find a list of Cookies that we use in the Cookies Schedule.
- You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
- You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
- It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
- For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
04 October 2018
What are cookies?
Cookies are widely used to facilitate and improve your use of our site by remembered you and your preferences, performing such essential functions as allowing users to remain logged in.
First party cookies are set by the site you are visiting – in this case our site.
Third party cookies are set by third parties to provide advertising or analytics services on our website.
How to control cookies
Most internet browsers enable you to choose to disable all cookies or disable only third party cookies. Most browsers accept cookies by default, but you can change this in your computer or device settings. For further support, consult your internet browser’s help menu or device documentation.
You can choose to prevent your data from being used by Google Analytics. Click here to access Google Analytics Opt-out Browser Add-on https://tools.google.com/dlpage/gaoptout/.
You can also choose to prevent your data from being used by Google Advertising. For more information visit https://support.google.com/ads/answer/2662922?hl=en-GB or to opt out visit https://tools.google.com/dlpage/optoutplugin/eula.html.
You can choose to delete cookies on your computer or device at any time. However, this may cause you to lose information such as login and personalisation settings.
For information about how Google uses advertising cookies please visit https://policies.google.com/technologies/ads.
All cookies used by our site are used in accordance with current UK and EU Cookie Law.
Before our site places cookies on your computer or device, you will be presented with a banner requesting your consent to place these cookies. By giving your consent to the placing of Cookies, you are enabling us LLP to provide a better experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of our may not function fully or as intended.
Types of cookies we use
For more information about types of cookies please visit https://policies.google.com/technologies/types
|Category of cookies||Why we use these cookies|
|Strictly Necessary||These cookies are essential for our website to perform basic functions.|
|Analytics||These cookies collect information on how users interact with our website, such as pages visited, time spent on our website and other analytical data. We use these details to improve how our website functions and to understand how to improve the experience for our users. These cookies also collect information on user location (to nearest town/city), language (when selected by the user), and demographic information such as age and gender (when selected by the user) but not identifiable information such as user name, address or contact information.|
|Advertising and Remarketing||We use these cookies for the purposes of remarketing our own services. We do not use these cookies to collect information to sell to third parties.|
Here at PA Answer, we take your privacy seriously and will only use your personal information to administer your account.
When you submit a support question or general enquiry, we collect your first name, last name and your email address so that we can correspond with you.
Your personal data will only be stored on this website ís database, we do not keep any other copies. Our Webhost is GDPR certified and compliant, so you can rest assured, your information is safe.
We use Google Analytics to track visitors on this site.
In order to be compliant with the new regulatory changes in regard to GDPR, Google has included a data processing amendment.
The data we collect will be processed anonymously and the Data sharing element has been disabled.
We don’t use other Google services in combination with Google Analytics cookies.
Freedom of Information request
Below we show you all of the data stored by our website. Select the data you wish the site owner to anonymise so it cannot be linked to your email address any longer. It is the sites owner responsibility to act upon your request. When your data is anonymized you will receive an email confirmation.
Requests Table & Rights of Data Subject
Right to Erasure Requests
The Data Subject (you) are able to submit a request to be erased from the site.
When a request is made, the Data Subject will receive an email confirmation to confirm the deletion request.
After email confirmation, the user request is added to the requests table for review by the Administrator.
If the Data Subject has content published on the site for any post types or comments, they will be added to this table. If they do not have any content, they will receive a confirmation of erasure request and be provided a 6 digit Token for safekeeping after erasure in case of recover data needs.
The requests table allows the Administrator to reassign any content to another user or delete it.
In the event of comments, the Data Subjectís content would be made anonymous.
Admin can also manually add users to the erasure requests table with a manual email search.
Right to Access Data Request & User Data Portability
The Data Subject can place a request to download their data.
After requesting their data, the user will receive a double opt-in confirmation email then the plugin will generate an XML or JSON file, which will be emailed to them for download with an expiration time of 48 hours.
Right to Rectify & Complaint Requests
The Data Subject can place a request to rectify data or file a complaint.
After making their request, the user will receive a double opt-in confirmation email and then add them to the table for admin to handle the request.
We use email marketing to keep you uptodate as well as newsletters.
Each of our mailshots is fully GDPR Compliant and will contain an opt-out notification if you no longer want to receive them.
For email marketing, we store the absolute minimum, your name and email address
- Collection and Use
- Personal Information in terms of this Policy
- Data Processing in terms of this Policy
- Information Received or Collected
- Data Submitted on Our Website
- Data submitted via Live Chat
- Data Submitted via Form Entry
- Data submitted upon purchase
- Personal Data attached to Subscriber Lists
- GDPR Implication for Users of the WPLC Plugin
- Your Data Shared and Disclosed
- Statistical Information
- Data Integrity
- Data Security
- Rights of Data Subjects
- Breach Notifications
- Data Transfers
- Amendments to this Policy
- In a Nutshell
- How to get in touch with us
- Data Submitted on Our Website
Collection and Use
For the purposes of this Policy, ‘personal information’ is regarded and relates to personally identifiable information of natural or juristic persons. Natural persons can be identified, whether directly or indirectly, by identification number or factors specific to his/her physical, mental, economical, social or cultural identity, including factors such as name, location or online identifier.
Notwithstanding the exceptions in terms of this Policy, Code Cabin and brand representative, WP Live Chat Support (hereafter WPLC) will not sell, rent or loan any personal information to third parties. Code Cabin and WPLC is committed to protecting the data you share with us.
Code Cabin and WPLC relies on your consent for data processing purposes. The GDPR (General Data Protection Regulation) defines consent as “…freely given, specific, informed…, a statement or by a clear affirmative action, signifies agreement to the processing of personal data…”.
Code Cabin and WPLC provides for granular consent processes in each instance where personally identifiable data is processed. Supporting the spirit and aim of data protection proposed by the GDPR, we have not only ensured for consent safeguards in our internal processes, so endeavouring to affect Privacy by Design, but have implemented GDPR compliance tools to assist Users of WPLC in communicating data protection to their site visitors. We have further provided for means by which certain data can be submitted on an anonymous basis, meaning there is no way to track the personal identity of such site visitors.
Subject to this Policy, in the course of utilizing Our Product or by way of communications with Code Cabin and WPLC, the following information may be collected and/or received per consent by you, the User or website visitor:
– Email address.
– Personal information, including name and surname.
– Contact information, including email address and social profiles.
– Business information, including company profiles, social profiles, websites, company name and address.
– Account information, including the use of third party services.
– Data, including use and access to Our Product, data transferred using Our Product and information submitted in regards to the use of Our Product.
Data submitted on our Website (https://wp-livechat.com/)
Data Submitted via Live Chat
As provider of a Live Chat service, WPLC hosts a live chat box on its site (https://wp-livechat.com/). If you, as website visitor, choose to get in touch with our agents via this Live Chat box, you must first consent to your data being processed for support/chat related purposes. Consent is verified by means of a check box and a notice (live chat consent clause) stipulating the data retention period. Based on this consent, WPLC may receive your name and email and information relating to your browser, operating system, type (new or returning visitor), agent ratings, visiting page url and any other personally identifiable information you may provide during the chat process. The latter information is utilized for enhanced support provision and specifically excludes location/IP tracking, so as to further ensure the protection of your personal data privacy. Once this chat data has been processed, it is stored on WPLC’s site database for the period specified in the live chat consent clause but may be requested, rectified or erased on your request, please contact us on firstname.lastname@example.org.
Data Submitted via Form Entry
Any data submitted to Code Cabin and WPLC by means of our contact form, is reserved for specific product support and query related purposes. If you choose to get in touch with our agents via this form, you must first consent to your data being processed. Consent is verified by means of a check box and a notice stipulating the details of the data controller (Code Cabin and WPLC) and the data retention period. Based on this consent, Code Cabin and WPLC may receive your name, email address and website url and information relating to the support query. This information is processed and stored on our internal support desk (not a third-party service, thereby providing an additional safety measure) and is retained for as long as reasonably required to act as reference for returning queries. You will be prompted to consent to the retention of you data for a reasonably required period. Only acting support agents of Code Cabin and WPLC will have access to said information, subject to the signing of a confidentiality agreement. Your information may be requested, rectified or erased upon request, please contact us on email@example.com.
Data submitted upon purchase
For completion of purchase Users of WPLC are required to submit information such as a name and email address for receipt of Our Product and to create an account via which the purchase of said product is verified. By voluntarily providing us with Account information, the User submits that he is the owner of the information provided or are otherwise authorized to provide it to Code Cabin and WPLC. This information, along with your transaction ID, is kept as reference to your opened account for as long as reasonably required. So as to give effect to the right of access to held information in terms of the GDPR, WPLC provides each purchaser with an individualised “account” area. From here, you may view, download, rectify or erase your data, please contact us on firstname.lastname@example.org.[Erasure of data comes with a stern warning that this terminates the license held by the User, as this is unchangeably attached to your personally identifiable data]. Code Cabin and WPLC in no way endeavours to make consent a condition of using our service, however, we require consent, as per regulation, to process your personal data and attach purchased licenses to it.
Code Cabin and WPLC further promoted the protection of your data by making use of payment solutions Stripe and PayPal, who also demonstrate compliance with the GDPR and have strict data protection measures in place.
Personal Data attached to Subscriber Lists
Such information is created, inputted, submitted, posted, transmitted, stored or displayed by you.
The collection of this data is on a strictly consensual basis for the purpose of rendering service in relation to Our Product or communicating marketing material. Information communicated may consist of notifications of new releases, updates, versions, changes, upgrades and/or future prospects. Code Cabin and WPLC will only communicate information reasonably relevant to the purpose of list subscriptions or information we reasonably believe will fall in your interest.
Furthermore, our newsletter campaigns will provide you with the needed information required by regulation: why we are emailing you, your previous consent and subscription and a clear option to opt out.
Code Cabin and WPLC will not communicate marketing information to you unless you have duly consented by subscribing to our newsletter lists. Code Cabin and WPLC do not generate automatic lists based on User or site visitors actions and where previously collected in this fashion, subscribers were prompted to re-subscribe and so confirm their consent.
You, as subscriber, may opt out of all subscriptions at any time, please contact us on email@example.com.
GDPR Implication for Users of the WPLC Plugin
As WP Live Chat Support not only conducts live chat activities, but is a provider of live chat software, we have implemented various checks and features to assist Users (of the Basic or Paid Version) in ensuring their chat data processing is inline with GDPR regulations.
WP Live Chat Support has provided for the addition of chat box consent clauses, data retention settings, a simplified way to export or erase chat data and informed Users of their responsibility towards GDPR compliance. Our quick guide to GDPR compliance can be found here.
Your Data Shared and Disclosed
Code Cabin and WPLC may share your personal data only in exceptional, limited circumstances as listed below:
- After you have consented to such action, and:
- In terms of certain business-related functions, such as functions regarding the maintenance of our databases, processing of payments or otherwise providing necessary software, storage or networking facilities to so effectively operate and manage Our Product.
- If, in bona fide spirit, it is reasonably necessary to:
- Satisfy law, regulation, legal provision or process or governmental request, assistance of investigation into the violations of this Policy, including fraud and theft and ultimately the protection of data and information of all Users and site visitors.
Code Cabin and WPLC undertake to apply discretion and caution when disclosing information for statistical purposes, so as to guard against disclosing any information by which you can be identified personally by any means whatsoever.
Employees, agents, officers and end-users within or outside of Code Cabin and WPLC will be given access to information they need to know only. Code Cabin and brand representatives undertake to not disclose personal data where not reasonably necessary or reasoned. Code Cabin and WPLC will take all appropriate legal, organizational and technical measures to protect the personal data of Users, site visitors, employees, agents, officers and end-users within or outside of Code Cabin and brand representatives with access to personal data will be held responsible for any privacy violations in terms of this Policy and, where appropriate, institute terminations of contracts and employment.
Notwithstanding the terms of this Policy set out above, you submits that Code Cabin and WPLC may share public information and anonymized aggregated data when involved in a merger, acquisition or sale of company. You further submits by consenting to our data processing, that Code Cabin and brand representatives may retain personal information in back-ups for a reasonable period of time, even after termination of the relationship between the latter party and the User or site visitor, unless erasure is otherwise requested. Upon request, Code Cabin and WPLC will delete, correct and/or block any personal information from further use and processing, unless restricted by law.
All personal information collected and processed is reviewed to ensure that Code Cabin and WPLC only store data needed to provide or improve Our Product. Reasonable steps are taken to ensure that personal information processed is accurate, complete and current. The User submits and has the right to provide Code Cabin and WPLC with relevant information and so update their profiles if and when information changes.
Code Cabin and brand representatives take reasonable steps to protect personal information from loss, misuse, disclosure, alteration or destruction. However, the Users submits, by using Our Product, that he understands the risks associated with transmitting data.
Cookie information employed by WPLC:
- wplc_name (the name entered in the name input field)
- wplc_email (the email entered in the email input field)
- wplc_cid (Cookie that stores the chat ID)
- wplc_hide (Cookie that hides the chat)
- wplc_minimize (Cookie that minimizes the chat)
- wplc_chat_status (Cookie that keeps track of current status of the chat, used to determine if the chat has been initiated or if the user is simply browsing the site)
Users who remove the use of ‘cookies’ will not be able to access certain services or products rendered by Code Cabin and WPLC. Code Cabin and brand representatives have no control over third party cookies and is therefore not covered by this Policy.
Children under the age of 18 are not to submit any personal information through or in relation to our service. Parents and guardians are called upon to help enforce this policy. If we become aware that a child under 16 has provided us with Personal Information, we will delete such information from our files.
Rights of Data Subjects
If you decide, at any time, that you no longer wish to receive marketing communications from Code Cabin and WPLC, please contact us on firstname.lastname@example.org. Please note, however, that even after you opt out from receiving marketing material, you may continue to receive essential product information.
Code Cabin and WPLC recognizes your right to request access and receive information about the Personal Information we hold, to update and rectify incomplete or inaccurate information, to restrict or object to the processing of your Personal Data, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to transfer your Personal Data to another company. Furthermore, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.
To update your preferences, ask us to remove your information from our mailing lists, delete your account or submit a request to exercise your rights under applicable law, please contact us at email@example.com.
Code Cabin and WPLC have ensured that certain processes are in place to meet a request of access, rectification, objection, erasure and opt-out is processed without undue delay and within the period of one (1) month.
Code Cabin and brand representatives will notify the relevant Users of any data breached within 72 hours of discovery and without undue delay.
Amendments to this Policy
- Should any provision/s in this Policy be held as invalid by a court of law, such provision/s shall be modified and thereafter interpreted so as to best accomplish the initial, now replaced provision to the fullest extent permitted by law; the remaining provisions shall remain unaffected.
In a Nutshell – TL;DR
- Code Cabin and WP Live Chat Support is committed to protecting the data you share with us.
- Code Cabin and brand representatives rely on the consent of Users and site visitors, or users who otherwise get in touch with us for product related queries, for data processing purposes.
- We have granular consent processes in place for every instance and separate purpose of data processing.
- We have provided for means by which we assist Users of WP Live Chat Support in ensuring their live chat practices are GDPR compliant.
- Information/data held by WP Live Chat Support may be request, rectified or erased at any time.
- WP Live Chat Support will only send you marketing material upon your consent, which may be withdrawn at any time.
- WP Live Chat Support takes reasonables measure to ensure the integrity and security of your data.
- Code Cabin and WP Live Chat Support acknowledges the right of our Users and site visitors in terms of the General Data Protection Regulation (GDPR).
- The retention and sharing of your personal information is regulated in terms of the GDPR.
- Our quick guide to GDPR compliance can be found here.
How to get in touch with us