General Privacy Notice
This privacy notice describes how the Peter Sanderson newsletter, (“we”, “our” or “us”) may collect, hold, use and disclose your personal information. This privacy notice explains how we collect, use and safeguard your personal information when you interact with our services. This privacy notice applies to all of our products, services and our Website.
We are responsible for any personal information that is used by us. This privacy notice is intended to provide individuals with clear and easily accessible information about our practices and policies with respect to personal information, and is intended to comply with the requirements of the Personal Information Protection Act 2016 (“PIPA”).
This privacy notice does not form part of a contract (if any) with us and does not confer any contractual right on you, or place any contractual obligation on us. The information in this privacy notice is an addition to any information provided to you at the point of collection. We may update or otherwise amend this notice at any time.
Definitions
- “Personal information” means any information about an identified or identifiable natural person.
- “Use” or “using”, in relation to personal information, means carrying out any operation on personal information, including, but not limited to: collecting, holding, organising, altering, transferring, disclosing, combining, blocking, erasing or destroying it.
- “Sensitive personal information” means any personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information.
- “Websites” means: petersanderson.ghost.io.
How we collect your personal information and your choices
Most of the personal information that we hold will have been provided by you (for example, when using our Website and signing up for a newsletter subscription).
If we use your personal information in a manner that is different than the purpose for which it was collected, then we will request your consent prior to such use. If we propose to use personal information for any purposes other than those described in this privacy notice and/or in a separate service notice, we will offer you an effective way to opt-out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this privacy notice and/or in a separate service notice, unless we have obtained your prior consent. You can decline to submit personal information to our Website or for any of our services, in which case we may not be able to provide our services to you.
Your personal information that we use
We may directly and indirectly collect and use the following types of personal information (including sensitive personal information):
- User account information (e.g. name, address, email address, date of birth, limited credit card or other payment account information (of which we can only view the last 4 digits and expiry date via the payment platform))
- User communications (e.g. when you e-mail or communicate with us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services)
- Newsletter and log information (e.g. sign up date, pages viewed, emails opened)
How we use your personal information
It is important to us that we use your personal information in a lawful and fair manner.
We use or may use your personal information: (i) for the purposes of providing you with our services; (ii) where it is publicly available and will be used for a purpose that is consistent with the purpose of its public availability; (iii) where it is necessary in order for us to comply with a provision of law that authorises or requires such use.
Some examples of how we use your personal information include:
- To provide our products and services to users
- To manage users accounts
- To communicate with you about your orders, products, services and promotions
- To audit, research and analyse our Website, products and services in order to maintain, protect and improve our Website, products and services
- To comply with legal and regulatory requirements
- Where otherwise reasonably necessary for legitimate business purposes
We may ask for your consent to certain uses which are not otherwise justified under one of the above bases. We shall provide clear, prominent, easily understandable, accessible mechanisms for you to give consent in relation to the use of your personal information, unless it can be implied from your conduct that you consent to the use of your personal information (excluding sensitive personal information) for the intended purposes that we have notified you of. Where consent is given, it may be withdrawn by you at any time, but this will not impact on any other lawful basis for use relied on by us. In some cases your refusal may mean that we are unable to provide our services to you as we will not have the personal information we believe necessary for the effective and efficient management of our relationship with you.
Where you provide to us personal information of a third party (e.g. friends or relatives), you must be authorised to share such personal information with us and we presume that you have obtained the individual’s consent where applicable.
We will keep your personal information no longer than is necessary for the purpose of its use, including in accordance with any statutory or regulatory requirements.
Sharing your personal information with others
Your personal information will only be used and disclosed as permitted by applicable law. Generally any personal information collected by us will remain under our custody and control, and will only be accessed and used internally by appropriate individuals in accordance with our access protocols. Externally we may share your personal information with the following:
- Our service providers (e.g. Ghost (newsletter platform) and Stripe (payments platform) with which we have a business relationship for their use or use on our behalf.
- Other third parties, where directed by you
- Our legal counsel, banks and financial institutions, auditors, consultants and other professional advisors
- Government, regulatory authorities or law enforcement if required by applicable law
Your personal information may also be accessed by third parties whom we work together with in connection with IT services (e.g. hosting, supporting and maintaining our IT systems).
International transfers of your personal information
Ghost and Stripe are not based in Bermuda, and so your personal information is kept on servers outside of Bermuda. Your data is accessed by us in the United Kingdom.
Security safeguards that we use
We will take reasonable steps and adopt appropriate safeguards against risk (including physical and IT based security measures and controls) proportional to the potential harm, sensitivity and context of the personal information which comply with applicable laws to protect your personal information against loss, unauthorized access, destruction, use, modification, disclosure or other misuse. Access to your personal information is also restricted to authorised employees, contractors and agents who require access for a permitted purpose to perform their employment functions, and whom have been advised as to its proper handling. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
This privacy notice applies to our services that are owned, operated or provided by us. We do not exercise control over the website platforms that the newsletter uses or appears on. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We are not responsible for the privacy practices or content of these sites, and we encourage you to review the privacy notices or policies of any third party sites that you visit.
Direct Marketing
We will use your contact details to keep you updated by sending email updates and advertisements with information about our products, services, promotional events and special offers and to conduct market research and surveys to improve our offerings. We do not share personal information that we collect about you with unaffiliated third parties for their use in marketing their products and services.
Your rights in relation to your personal information
You have certain rights with respect to your personal information, and you may submit a reasonable written request to us to:
- Access (i) your personal information that is in our custody or control; (ii) the purposes for which we have been or are using your personal information; and (iii) the names of persons or types of persons and circumstances for which your personal information has or is being disclosed
- Correct an error or omission in any of your personal information which is under our control
- Block which is to cease, or not to begin, using your personal information for the purposes of advertising, marketing, or public relations, or where the use of that personal information is causing or is likely to cause substantial damage or substantial distress to you or another individual
- Erase or destroy personal information about you where that personal information is no longer relevant for the purposes of its use (however, there may be circumstances where we will be legally entitled to retain it)
Any request must be in writing and provide sufficient detail to enable us to identify the personal information to which the request relates. In certain circumstances (described below), we may not be obligated to comply with a rights request, and you can request a review by the Privacy Commissioner of our decision, action or failure to act, and you may initiate a complaint against us with the Privacy Commissioner.
We may refuse to access to personal information in, but not limited to, the following circumstances:
- Personal information is protected by legal privilege
- Disclosure of the personal information would reveal confidential information or of a third party that is of a commercial nature and it is not unreasonable to withhold that information
- Personal information is being used for a current disciplinary or criminal investigation or legal proceedings, and refusal does not prejudice the right of the individual to receive a fair hearing
- Personal information was used by a mediator or arbitrator, or was created in the conduct of a mediation or arbitration for which the mediator or arbitrator was appointed to act under an agreement or by a court
- Disclosure of the personal information would reveal the intentions of us in relation to any negotiations with the individual to the extent that the provision of access would be likely to prejudice those negotiations.
Contacting us and our Privacy Officer
If you have any questions about this privacy notice or to request more details about your rights and how we collect, use and disclose your personal information, please contact our Privacy Officer at:
Email: bermudareview @ gmail dot come
Complaints
If we receive a complaint at our address or via our Website, our policy to contact the complaining individual regarding their concerns within a reasonable timeframe. We will cooperate with regulatory authorities, including the Office of the Privacy Commissioner for Bermuda, to resolve any complaints regarding personal information that cannot be resolved between us and an individual.
Privacy notice updates
We regularly review our compliance with this privacy notice, which is subject to change in accordance with changes to applicable laws or our internal policies and procedures. The date below indicates when this privacy notice was last revised.
Any changes to this privacy notice will be effective upon publication of the revised privacy notice.