1 – Our core beliefs regarding user privacy and data protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
2 – Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regard to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- Australian Privacy Act 1988 (APA)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories. If you are unsure whether this site complies with your country of residence’s specific data protection and user privacy legislation, you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.
3 – Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to understand better how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser, and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address, which could be used to personally identify you, but Google does not grant us access. We consider Google a third-party data processor (see section 6.0 below).
GA uses cookies, details of which can be found on Google’s developer guides. FYI, our website uses the analytics.js implementation of GA.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
In addition to Google Analytics, this website may collect* information (already held in the public domain) attributed to the IP address of the computer or device being used to access it. The information is supplied to us by Whoisvisiting.com. Whoisvisiting.com is a service offered by Whoisdata Limited. The Whoisvisiting system does not use your IP address to identify you, the individual, in any way. No cookies are used by the Whoisvisiting system.
* The Whoisvisiting system will only look for information when a static IP address is being used. Differences between a static and dynamic IP address.
More information about how Whoisvisiting uses IP addresses.
3.2 Contact forms and email links
Should you contact us using the contact form on our Contact Us page or an email link like this one, none of the data you supply will be stored by this website or passed to / processed by any of the third-party data processors defined in section 6.0. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS (sometimes known as SSL), meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
3.3 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third-party data processor (see section 6.0 below). The email address you submit will not be stored within this website’s database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links in any email newsletters we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age, you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic newsletter-style emails from us.
4 – How we store your personal information
As detailed in section 3.2 above, if you submit a form on this website, some personal information will be stored within this website’s database. This is currently the only time personal data will be stored on this website. This data is stored in an identifiable fashion, a limitation of the content management system that this website is built on (WordPress). Shortly, we aim to change the storage of this data to a pseudonymous fashion, meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymization is a recent requirement of the GDPR, which many web application developers are currently working to implement fully. We are committed to prioritizing it and will implement it on this website as soon as possible.
5 – About this website’s server
This website is hosted by Kinsta
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
6 – Our third-party data processors
We use several third parties to process personal data on our behalf. These third parties have been carefully chosen, and they all comply with the legislation in section 2.0.
- Google (Privacy policy)
- Mailchimp (Privacy policy)
7 – Data breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8 – Data controller
The data controller of this website is Groundsailer Media B.V., a Dutch Private limited Company with company number 66371295
Whose registered office is:
Kennemerstraatweg 115
ALKMAAR, 1814 GE
THE NETHERLANDS
9 – Data protection officer
Mr. Sake Marijn Rietveld
Director, Groundsailer Media B.V.
Telephone: + 31 6 0816 90 816
Email: sri@groundsailer.com
10 – Changes to our Privacy Policy
This privacy policy may change occasionally in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend checking this page occasionally for any policy changes.
11 – Governing law
This agreement shall be construed and enforced by the laws of The Netherlands.
Groundsailer Media B.V. is listed in the trade register of the Chamber of Commerce in Alkmaar, The Netherlands, under number 66371295.