Revised: 24 January 2020

Data Controller

Debbie Frank is a Data Controller. Our Data Protection Office is Debbie Frank who can be contacted on [email protected]

Introduction

Debbie Frank owns the debbiefrank.com website and is committed to protecting your personal information in accordance with the General Data Protection Regulations (‘GDPR’).

This Privacy Notice explains how Debbie Frank collects, use, shares, discloses or otherwise processes personal information we hold about you as collected through the debbiefrank.com. It also explains your rights under the GDPR.

What information we hold and where has it come from

Subscribers and Premium Membership Members

When you subscribe to the website or join as a premium member we collect the information that you provide online when you complete the details within the online forms.

Website users

We automatically collect information when you visit our website. This includes information about your device and its geographical location. We also collect information including your IP address and other device identifier information. We may also collect website usage information and statistics on your interactions.

We also store information on tasks you perform on the site and whether you have logged in successfully.

We may also collect information from cookies already stored on your device. See our Cookies Policy below.

Comments on Blogs

Comments you make in response to blogs are public.

Payment Processes

When payment details are entered such as during the subscription process or when purchasing a report, the payment details are sent directly to PayPal/Stripe who process the transaction on our behalf.

Other contacts you may make

Any contact you make with Debbie Frank on Twitter whether via direct messages or otherwise is not processed.

How do we use your data

Processing of your data is only permissible where there is a lawful basis.

Contractual

We may process your data so that we can fulfil our contract to you where you have made a purchase or registered as a free or premium member. This enables us to provide the services that you have purchased or registered for.

Legitimate Interest

We may process your data so that we can send you emails which may include some promotional content. We consider that we have a legitimate interest in doing so. This means we have considered the emails we send helps us provide a better service to you.

We process location and website usage patterns so that we can improve our understanding of users and their preferences and the website itself. This improves your experience of the website and helps us improve its performance.

We process information when you access the site from a mobile device so that we can better understand and improve how our website works on your device. This data is anonymised.

We process information when you contact our support services or make other enquiries, so that we may respond.

We will always ask your consent where there is no lawful basis for processing.

Data Security

Access to your account is controlled by a unique username and password.

We keep your information secure when processing by use of passwords and restricting user access where access is not necessary. We also employ physical and managerial measures to safeguard your information.

The information we collect is transferred to and stored on a server based in the United States which has the Privacy Shield certification. The EU-US Privacy Shield scheme was approved by the European Commission on I August 2016 as providing adequate protection to allow personal data to be transferred to the United States and places stronger obligations on US companies to protect EU members’ personal data.

Data Retention

Your information is retained as long as necessary for the uses set out in this policy or while there is a legitimate reason for doing so. Requests for deletion of your data can only be complied with if there are no technical, legal or regulatory reasons that do not allow us to do so.

How we share your data

We pass your information to our processors so that they may provide services on our behalf. We have agreed terms of service which means that your data can only be used in accordance with our instructions.

We may share your information with third party service providers including cloud storage systems, backup service providers, support management platforms and content support teams to help us deliver our services to you. We do not authorise these companies to use your data for any other purpose.

In the event of a sale or purchase of a business or assets, we may share your data with the prospective buyer or seller in strict confidence.

We may disclose your information when we are required by law to do so. We may also disclose your information to enforce our rights or the rights of others or to assist with the detection of crime or fraud.

We may also disclose your information to ensure our services are used appropriately such as when offensive or objectionable content is posted to the forums so that we are able to stop this behaviour.

We may also disclose your information to protect our business interests where any malicious activity or threats to the website are identified.

Your data protection rights

Access rights

You have the right to the access personal data which we hold about you. This is called a subject access request and must be made to the data controller who can be contacted using the address shown above.

Rectification rights

You have the right to have your personal data corrected if it is inaccurate or incomplete.

Rights to object, erase or restrict processing

You have the right to object or restrict our processing of your information or to request that we erase it. We will consider your requests as there may be circumstances or legal requirements that require us to continue processing your data.

Right to transfer data

In some circumstances, you have the right to request transfer of your data to another organisation.

Requests should be emailed to the data controller at the address shown at the top of this page.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.

Right to complain

You also have the right to complain to your national regulator. In the UK the regulator is the Information Commissioners Office (‘ICO’).

Cookie Policy

Cookies are small text files that are placed on your device when you first visit a webpage. They are used on most websites to make the website work, improve its performance and provide information on website usage to website owners.

We can only place cookies on your device with your consent. There is a notice on our home page which describes how we use cookies. This notice will give you an opportunity to consent to our use of cookies for the purposes described in this policy and our website Privacy Notice.

Types of Cookies used

We use session cookies and persistent cookies.

Session cookies are temporary and only stay on your device while you are on the platform. Persistent cookies will remain until you delete them, subject to its ‘lifetime’ or duration.

We use cookies for the following

Authentication: to identify you and whether you have logged in. It will keep you logged in as you move from page to page on the website avoiding having to log in to each page you visit.

Security: to enables and supports security features, prevents fraud and protects your data from unauthorised access.

Preference and features: to help us save your preferences and so provide you with relevant content.

Analytics and performance: this helps identify how the website is used and monitor performance. It helps us fix errors, understand and improve services, research and test out different features and monitor how our visitors reach our sites.

We use cookies that are necessary for us to provide the services you use. You cannot opt out of all cookies used. You may disable placement of some (but not all) cookies by setting your browser to decline cookies, though this may worsen your user experience. Additionally, you can also control, manage and/or delete cookies via your browser settings.

A useful resource for information about deleting and controlling cookies can be found at www.aboutcookies.org

You can also manage cookies through the settings on your browser.

You can opt out of tracking by Google Analytics and Google Analytics Demographics and Interest Reporting services by visiting Google Ads Settings or by downloading the Google Analytics Opt-Out Browser Add-on.

Do Not Track Signals

We do not respond to ‘do not track’ signals and similar settings or mechanisms. When you use the Platform, we try to provide a customized experience.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

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