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Privacy policy

Data protection at a glance

General information

The following information provides a basic overview of what happens to your personal data when you visit this website. Personal data is all data that could be used to personally identify you. See the below for detailed information on the topic of data protection.

Data collection on this website: general and mandatory information

Who is responsible for the collection of data on this website?

The website operator, Berlie Doherty, is responsible for the processing of data on this website.

contact@berliedoherty.com

How do we collect your data?

On the one hand, your data is collected if you provide us with it. For example, this could be data that you enter into a contact form.

Other data is recorded by our IT systems when you visit our website, either automatically or after you have granted permission. This is predominantly technical information (for example internet browser, operating system and the time the page was requested). This information is recorded automatically as soon as you visit our website.

What do we use your data for?

Some of this data is collected in order to ensure the website is presented without errors. Other data can be used to analyse your user behaviour.

What rights do you have in respect of your data?

At all times, you have the right to receive, free of charge, information on the origin and recipient of your stored personal data, as well as on the purpose it is used for. You also have the right to demand that this data be corrected or deleted. If you have granted permission for processing of your personal data, you can revoke this permission for future effect. Furthermore, in certain circumstances you also have the right to demand that this processing of your personal data is restricted. You also have the right to lodge a complaint with the responsible regulatory authority.

In order to exercise this right, or if you have any other questions on the topic of data protection, please contact us:

data@berliedoherty.com

Revoking your consent for data processing

Many data protection operations are only possible with your explicit consent. You can revoke previously granted permission at any time. The legality of the data processing that occurs up to the point you revoke your consent remains unaffected by this revocation.

Right to object to data collection in particular circumstances, as well as to direct marketing

If data collection occurs on the basis of our legitimate interest, you always have the right, for reasons resulting from your own particular situation, to lodge an objection to your personal data being processed. This also applies to profiling based upon these provisions. Please see this privacy policy for details of the respective legal basis upon which this processing occurs. Should you lodge an objection, we will no longer process your affected personal data unless we can prove compelling legitimate grounds for processing it which outweigh your interests, rights and freedoms, or if processing is necessary for asserting, exercising or defending legal claims.

If your personal data is used for direct marketing purposes, you have the right at all times to lodge an objection to your personal data being processed for the purposes of this type of marketing. This also applies to profiling, insofar as it is linked to such direct marketing. If you lodge an objection, your personal data will then no longer be used for direct marketing purposes.

Right to appeal to the responsible regulatory authority

In the event of a breach of the GDPR, the affected party has the right to appeal to a regulatory authority. See the bottom of this page.

Right to data portability

You have the right to receive, or for third parties to receive, the data that we process using automated processes on the basis of your consent to do so, or for us to fulfil a contract. This must be made available in a common machine-readable format. Should you demand that the data is transferred directly to your representative, this only occurs insofar as this is technically possible.

SSL/TLS encryption

For security reasons, and in order to protect the transmission of confidential data, such as for example orders or enquiries that you send us in our function as website operator, this website uses SSL/TLS encryption. You can recognise a secure connection by the fact that ‘https’ appears in the browser’s address bar instead of ‘http’, and by the padlock icon in your browser bar.

When SSL/TLS are activated, the data you transfer to us cannot be read by third parties.

Information, deletion and correction

As part of the applicable legal regulations, you have at all times the right to free-of-charge information on your stored personal data, its source and recipient and the purpose for the data processing. For more information, or if you have any other questions on personal data, you can contact us at the following address: data@berliedoherty.com.

Right to restrict processing

You have the right to demand that processing of your personal data is restricted. To do so, you can contact us at any time at the following address: data@berliedoherty.com. You have a right to restrict processing in the following cases:

  • If you dispute the accuracy of the personal data we store, we generally need time to check this. For the duration of this inspection, you have the right to demand that processing of your personal data is restricted.
  • If processing of your personal data occurred/occurs illegally, you can demand that data processing is restricted rather than the data being deleted.
  • If we no longer require your personal data, but if you however require it for exercising, defending or asserting legal claims, you have the right to restrict processing of your personal data rather than it being deleted.
  • If you raise an objection, consideration must be made of your interests and ours. As long as cannot be determined whose interests take precedence, you have the right to demand that processing of your personal data is restricted.

If you have restricted processing of your personal data, then apart from its storage, this data may only be processed with your consent, or for asserting, exercising or defending legal claims, or for protecting the rights of another natural person or legal entity, or for reasons of substantial public interest.

Analysis tools and other third party tools

When you visit our website, your surfing behaviour is statistically analysed. This occurs predominantly using analysis programs.

Matomo Analytics

We use Matomo Analytics to analyse website visitors’ behaviour. This enables us to identify potential pitfalls such as ‘not found’ pages, search engine indexing issues and how often the different pages of the websites are visited, and how long visitors spend on them.

Once the data has been processed (ie the number of visitors reaching a ‘not found’ page, or only viewing one page of the website), Matomo generates reports for website owners to take action, for example by changing the website structure, the layout of certain pages or improving the website content.

We have configured Matomo Analytics to neither set nor use cookies.

Instead, it tracks visitors to our website on the basis of ‘fingerprinting’. For example, that someone in country X using operating system Y, web browser Z and with screen resolution Q visited website pages A, B, C and D.

Although we have configured Matomo to enable us to see which countries website visitors come from, we have also configured it to anonymise visitors’ IP addresses by removing the final two sections. This means that we do not receive accurate information about website visitors’ location within their respective country.

Matomo processes the following personal data:

  • Date and time of the visit
  • Title of the page being viewed
  • URL of the page being viewed
  • URL of the page that was viewed before the current page
  • Screen resolution
  • Time in the user’s local timezone
  • Files that were clicked and downloaded
  • Clicks on links to external domains
  • Page generation time
  • Country
  • The browser software’s user agent setting
  • The browser software’s language setting

This processing of personal data using Matomo is based on our legitimate interest in ensuring that our website is as engaging and relevant as possible for our visitors, and that they are easily able to find the information they are looking for.

It enables us to identify areas where improvement is required, and to react accordingly by improving the website’s structure, layout, design and content. As a result, users directly benefit.

Without collecting this personal data, we would not be able to provide you with the content and service we currently provide. Your data is only used to improve users’ experience on our website and to help them find the information they seek.

Recipient of the personal data

The personal data received through Matomo is sent to:

  • The website operator
  • The website operator’s hosting company, whose address is:

Hosting UK
11-21 Paul Street
London
EC2A 4JU

Details of transfers to third countries, and safeguards

Matomo data is hosted in the United Kingdom, and is therefore subject to the UK GDPR. Site backups are stored in the EU, and are therefore subject to the EU GDPR.

Retention period and criteria used to determine the retention period

We keep the personal data captured by Matomo for a period of 180 days. This period provides us with enough time to be able to carry out meaningful analyses of website visitors’ behaviour, so that we can review and improve our website.

Your rights as a data subject

As Matomo processes personal data based on our legitimate interest, you can exercise the following rights:

  • Right of access: you can ask us at any time to access your personal data.
  • Right to erasure: you can ask us at any time to delete all the personal data we are processing about you.
  • Right to object: you can object to the tracking of your personal data by using the opt-out feature below.

Your right to withdraw consent at any time

You can withdraw your consent to tracking by Matomo Analytics by clicking here:

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

Opting out from us using Matomo Analytics to process your personal data in order to improve our website does not result in any consequences for you regarding your use of our website.

The right to lodge a complaint with a supervisory authority

If you think that the way we process your personal data with Matomo Analytics is infringing the law, you have the right to lodge a complaint with a supervisory authority. See the bottom of this page.

Hosting and content delivery networks (CDNs)

External hosting

This website is hosted by an external service provider (hosting company). The personal data recorded on this website is stored on the hosting company’s servers. This includes for example IP addresses, contact enquiries, meta data and communication data, contractual data, contact details, names, web page access details and other data generated by a website.

A hosting company is used in order for us to fulfil contractual obligations to current and potential customers and to ensure secure, fast and efficient availability of our web presence by a professional provider.

Our hosting company will only process your data insofar as required to fulfil its contractual obligations, and will follow our instructions in relation to this data.

Server log files

The provider of this website automatically collects and stores information that your browser automatically transfers to us in server log files. This information spans:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Referrer URL
  • Host name of the computer accessing the website
  • IP address

This data is not merged with other data sources.

This information is collected on the basis of our legitimate interest in ensuring our website is presented without technical problems and in optimising it – the recording of server log files is required for this.

Cookies

This website does not ordinarily set cookies, either directly or from third parties (third party cookies). Certain user actions can result in a cookie being set. Any such instances are mentioned elsewhere in this privacy policy.

Contact form

If you send us enquiries using the contact form, we will save the details you provide in the contact form, including the contact details you provide, for the purpose of dealing with your enquiry and for the event of any follow-up enquiries. We will not pass this data to other parties without your permission.

Processing of this data occurs on the basis of our legitimate interest, insofar as your enquiry relates to the fulfilment of a contract or is required for performing contractual duties. In all remaining cases, processing occurs on the basis of our legitimate interest in being able to effectively process enquiries that are sent to us, or your consent having been granted, provided this has been requested.

We retain the data you send to us in the contact form until you ask us to delete it, revoke your consent for us to store it, or the purpose for storing the data no longer applies (for example, after processing of your enquiry has been completed). Mandatory legal provisions – especially those regarding statutory data retention periods – remain unaffected.

Enquiries by email

If you contact us by email, we will store and process your enquiry, including the personal information contained within it (name, enquiry), for the purpose of dealing with your matter. We will not pass this data to other parties without your permission.

Processing of this data occurs on the basis of our legitimate interest, insofar as your enquiry relates to the fulfilment of a contract or is required for performing contractual duties. In all remaining cases, processing occurs on the basis of our legitimate interest in being able to effectively process enquiries that are sent to us, or your consent having been granted, provided this has been requested.

We retain the data you send to us as part of contact enquiries until you ask us to delete it, revoke your consent for us to store it, or the purpose for storing the data no longer applies (for example, after processing of your enquiry has been completed). Mandatory legal provisions – especially those regarding statutory data retention periods – remain unaffected.

Comment function on this website

The comment function on this website saves other information in addition to your comment. This information includes the date and time the comment was created, your email address and, if you are not posting anonymously, the user name you chose.

Storage of your IP address

Our comment function stores the IP addresses of users who submit comments. We require this data so that, in the event of legal infringements such as libel, we can take legal action against the person who wrote the comment.

Length of time comments are stored

The comments and data relating to them (for example IP addresses) are stored and remain on this website until the content you commented on is completely deleted, or until the comments have to be deleted on legal grounds (for example, libellious comments).

Legal basis

Comments are stored on the basis of our legitimate interest. You can revoke permission previously granted at any time. To do so, simply state this in an email. The legality of the data processing procedures that have already occurred remains unaffected by this revocation.

Affiliate marketing

Amazon Associates

This website contains affiliate links, as the site owner is a member of the Amazon Associates affiliate marketing programme. If you buy items using these links, the site owner receives a commission, at no extra cost to you.

These so-called affiliate links are just standard text or image links.

This website does not use Amazon’s tools for the purpose.

This is in order to prevent data transfer to Amazon when people visit this website.

Only if you arrive on Amazon’s website as a result of clicking one of these links can Amazon see that you have visited this website with your IP address.

Social media

Social media plugins with Shariff

This website uses social media plugins (eg Facebook, Twitter and Pinterest).

You can generally recognise these plugins by the use of the respective social media logos. To guarantee data protection on this website, we only use these plugins with the so-called Shariff solution. This application prevents the plugins integrated into this website from transferring the data collected as soon as you first visit this website to the respective provider.

A direct connection to the provider’s server is only established if you activate the respective plugin by clicking its button (granting consent). Once you activate this plugin, the respective provider receives the information that you have visited this website with your IP address. If, at the same time, you are logged into the respective social media account (for example Facebook), the respective provider can link your visit to this website to your user account.

Activation of this plugin represents granting your consent. You can revoke this consent, with future effect, at any time.

Plugins and tools

YouTube with enhanced data protection

This website features embedded YouTube videos. The operator of the YouTube platform is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in enhanced data protection mode. According to YouTube, using this mode means that YouTube does not receive any personal information about visitors to this website before they view a video. However, using this enhanced data protection mode does not necessarily prevent data being transferred to YouTube’s partners.

As soon as you start a YouTube video on this website, a connection to YouTube’s servers is established. The YouTube server will also receive information about which pages on our website you have visited. If you are logged into your YouTube account, you enable YouTube to directly link your surfing behaviour to your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, after starting a video, YouTube can set various cookies on your device, or use similar recognition technologies (such as device fingerprinting). In this way, YouTube is able to receive information about visitors to this website. This information is used in order to capture video statistics, improve user-friendliness and prevent attempted fraud, among other reasons.

In some circumstances, starting a YouTube video can also trigger other data processing procedures, over which we have no control.

We make these YouTube videos available on our website in the interest of our being able to create an appealing web presence. This represents a legitimate interest on the basis of Article 6 1 ( f) GDPR.

You can find more information about YouTube’s data protection in their data privacy policy at https://policies.google.com/privacy?hl=en.

Information on data transfer to the USA

Among other things, our website uses tools from businesses based in the USA. If these tools are active, your personal data can be transferred to servers in the USA belonging to the respective businesses. We would like to point out that the USA is not a secure third country in respect of EU data protection law. US businesses are obliged to supply personal data to security agencies, without the people affected being able to take legal proceedings. It therefore cannot be ruled out that US authorities (such as the security services) process and analyse your personal data found on US servers, and store it for long periods. We have no influence on these data processing activities.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at data@berliedoherty.com.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:            

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://ico.org.uk

19 April 2021

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