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At the Lakestelecom your privacy
is important to us. Lakestelecom is a trading name of John Steel who is a sole
trader and this policy should be taken to apply regardless of whether services
are provided by Lakestelecom or John Steel directly, both Lakestelecom and John
Steel are hereafter referred to as the Company. We operate to fundamental
principles which are in accordance with the GDPR and any other relevant
legislation:
We only collect personal information from you that is
legitimately needed for us to fulfil our obligation to you as a client of the Company.
We store personal information for only as long as we have a
reason to need it or are required to for legal reasons.
We aim to make it as simple as possible for you to determine what
information we hold on you and how you can correct any errors
We aim for full transparency on how we gather, use, and share
your personal information.
Below is the Company. privacy policy, which incorporates and
clarifies these principles.
Who We Are and What This Policy Covers
Lakestelecom and John Steel (hereafter the Company) has
been formed to provide website hosting, development and support.
John Steel is a sole trader and the Data Controller under
the terms of the General Data Protection Regulation. He may be contacted via
their secretary using the email address support@johnsteel.net .
This Privacy Policy applies to information that we collect
about you when you subscribe to the newsletter or join any group supported by
the Company , sign up to any facilities on the Company website, purchase items
from the Company or communicate with the Company for any other reason.
Throughout this Privacy Policy we'll refer to our website,
mobile applications and other products and any services provided collectively
as "Services."
Below we explain how we collect, use, and share information
about you, along with the choices that you have with respect to that
information.
Privacy Policy Changes.
Although most changes are likely to be minor, the Company
may change its Privacy Policy from time to time. The Company encourages
visitors to frequently check this document for any changes to its Privacy
Policy. If we make changes, we will notify you by revising the change log
below, and, where possible, we may provide additional notice (such as adding a
statement to our homepage or sending you a notification through e-mail or your
Membership Account) though this is not guaranteed and failure to do so will not
affect this policy and its validity. This policy is effective from 26th
May 2018.
If you have any questions about this Privacy Policy, please
contact John Steel.
Purpose of the processing
We only collect information about you if we have a reason to
do so, for example, to provide our Services, to communicate with you in
relation to your subscription or any purchases you may make, to make our Services
better or deal with your communication.
The lawful basis on which we process this information
We collect and process most information on the basis of contract.
In limited cases we may process information based on consent, but where that is
the case it will be clearly shown and you will have to positively state that
you provide consent. In some cases we have a legal obligation to process and
retain records.
The Company considers that the use of information provided
by users of the Company facilities will have a reasonable expectation that the
data provided will be processed in line with the provision or use of Company
facilities in ways they would reasonably expect.
Any person has a right to object to the processing of their
data, The Company however believes there is compelling reason for the
processing of basic data as they are unable to fulfil their responsibilities
without that information being processed. Without the processing of data it is
not possible for you to be a subscriber to any of the services provided by the Company
and in subscribing to any services provided by the Company you recognise this
requirement.
You do however have the right to object to direct marketing,
if you wish to be removed from direct marketing distributions then you should
inform the Company of this by contacting their secretary. This will not affect the
Company's ability to send you communications on non-marketing matters in
connection with your subscription or use of Company services.
Requesting access to your personal data
Under data protection legislation, you have the right to
request access to information about you that we hold. To make a request for
your personal information, contact the secretary of the Company this can be
done via the contact page on the website.
You also have the right to:
object to processing of personal data that is likely to cause, or
is causing, damage or distress
prevent processing for the purpose of direct marketing
object to decisions being taken by automated means
in certain circumstances, have inaccurate personal data
rectified, blocked, erased or destroyed; and
claim compensation for damages caused by a breach of the Data
Protection regulations
If you have a concern about the way we are collecting or
using your personal data, we ask that you raise your concern with us in the
first instance so that we can rectify the situation. Alternatively, you can
contact the Information Commissioner's Office at https://ico.org.uk/concerns/
Information We Collect
We collect information in two ways: if and when you provide
information to us and automatically through operating our Services
Information You Provide
to Us
This information is normally
provided when you apply for or renew one of our services, though it may also be
requested when setting website preferences, making purchases or contacting us.
Every attempt will be made to make it clear why we are collecting this
information.
Typically we will collect the
following information:
We collect information that you provide to us when applying for
or renewing any services. The amount and type of information depends on the
context and how we use the information. Here are some examples:
Website facilities: If you wish to use any website facility such
as being advised of new items we ask you to provide your name and email
address.
Communications with Us : You may also provide us information when
you respond to surveys, or communicate with us.
Purchases: We may collect information when you make purchases
from the Company, as well as your name and address and email address, this may
include financial data such as your PayPal details.
Information We Collect Automatically
We also collect some information
automatically:
Log Information: Like most online service providers, we collect
information that web browsers, mobile devices, and servers typically make
available, such as the browser type, IP address, unique device identifiers,
language preference, referring site, the date and time of access, operating
system, and mobile network information.
Usage Information: We collect information about your usage of our
Services. For example, we collect information about how many times you visit
the website and which pages you visit, however this information does not
contain any direct personal data and is processed using your IP number.
Location Information: We may determine the approximate location
of your device from your IP address. We collect and use this information to,
for example, calculate how many people visit our Services from certain
geographic regions and possibly to alter the content presented based on your
location.
Information from Cookies & Other Technologies: A cookie is a
string of information that a website stores on a visitor's computer, and that
the visitor's browser provides to the website each time the visitor returns. The
Company uses cookies to help identify and track visitors, usage, and access
preferences for our Services. For more information about our use of cookies and
other technologies for tracking, including how you can control the use of
cookies, please see the section in this policy that covers cookies
Automatic processing
When you provide data to the Company,
for example when joining, renewing subscriptions or making purchases, or using
any forms on the website, you are responsible for ensuring you input your data
correctly. We will use that data as supplied, for example automatic confirmation
e-mails may be sent that contain some of the data you have supplied, if you
have incorrectly entered your e-mail it could be sent to a different person, we
have no way of validating information provided and therefore have to use it as
supplied.
How We Use Information
All the personal data we process
is processed in the UK, for the purposes of IT hosting and maintenance this
information is located on servers within the United Kingdom. No 3rd parties
have access to your personal data unless it is essential for them to provide
services to us or the law allows them to do so.
If however you access our
services from outside the United Kingdom it is possible your data may be
temporarily held on servers or other caching points that are outside the UK, we
have no control over this.
We have a Data Policy in place to
oversee the effective and secure processing of your personal data.
We use information about you as
mentioned above and as follows:
To provide our Services - for example, to send you our Newsletter
or to send you emails with the details you have requested;
To further develop our Services - for example by adding new
features that we think our users will enjoy or will help them to use our
facilities more efficiently;
We use your supplied interests to provide you with relevant
material and to contact you about topics you may be interested in;
To monitor and analyse trends and better understand how users
interact with our Services, which helps us improve our Services and make them
easier to use;
To monitor and protect the security of our Services, detect and
prevent fraudulent transactions and other illegal activities, fight spam, and
protect the rights and property of the Company and others;
To communicate with you about offers and promotions offered by the
Company and others we think will be of interest to you, solicit your feedback,
or keep you up to date on the Company and our products;
To personalize your experience using our Services, provide
content recommendations and serve relevant advertisements.
Sharing Information
How We Share Information
We do not sell our users' private
personal information to any other party and information is only disclosed to 3rd
parties if it is necessary for us to fulfil our obligations or required by law.
We share information about you in
the limited circumstances spelled out below and with appropriate safeguards on
your privacy:
Suppliers: We may disclose information about you Suppliers that
need to know the information in order to help us provide our Services or to
process the information on our behalf. We Suppliers to follow this Privacy
Policy for personal information that we share with them. Examples of this would
be the supply of limited data to our domain registrar to enable your domain to
be registered.
Third Party Vendors: We may share information about you with
third party vendors who need to know information about you in order to provide
their Services to us. This group includes vendors that help us provide our Services
to you (like payment providers that process your credit and debit card
information). We require vendors to agree to privacy commitments in order to
share information with them.
Other third parties: We may share information with other third
parties who need the information to enable us to process your orders, for
example we will share your information in the process of setting up a standing
order with your bank. In all cases you will have a reasonable expectation that
your data will need to be shared to achieve what you have requested or
authorised.
As Required by Law: We may disclose information about you in
response to a subpoena, court order, or other governmental request.
To Protect Rights and Property: We may disclose information about
you when we believe in good faith that disclosure is reasonably necessary to
protect the property or rights of the Company, third parties, or the public at
large. For example, if we have a good faith belief that there is an imminent
danger of death or serious physical injury, we may disclose information related
to the emergency without delay.
Business Transfers: In connection with any merger, sale of the Company
assets, or transfer of all or a portion of the Company to another entity, or in
the unlikely event that the Company goes out of business or enters bankruptcy,
user information could be one of the assets that is transferred or acquired by
a third party. If any of these events were to happen, this Privacy Policy would
continue to apply to your information and the party receiving your information
may continue to use your information, but only consistent with this Privacy
Policy.
With Your Consent: We may share and disclose information with
your consent or at your direction. For example, we may share your information
with third parties with which you authorize us to do so, such as the social
media services, or we may publish limited personal details about new members in
our Newsletter.
Aggregated and De-Identified Information: We may share
information that has been aggregated or reasonably de-identified, so that the
information could not reasonably be used to identify you. For instance, we may
publish aggregate statistics about the use of our Services.
Published Support Requests: And if you send us a request (for
example, via a request email or one of our feedback mechanisms), we reserve the
right to publish that request in order to help us clarify or respond to your
request or to help us support other users.
Information Shared Publicly
Information that you choose to
make public. That means, of course, that information like your public profile, or
other content that you make public on our website or any other website
associated with us but controlled by other entities such as Facebook or Twitter,
and your "likes" and comments on other websites that use our Services, are all
available to others. Public information may also be indexed by search engines
or used by third parties. Please keep all of this in mind when deciding what
you would like to share.
This includes information such as
family trees and other genealogical interests that you have asked us to
publish. Although it may be published in a members only newsletter or journal,
we have no control over circulation of that media and it will be available in
libraries and therefore accessible by the general public.
Data Retention
We only retain your data as long as is necessary to serve
our legitimate interests. There are categories which have different criteria
for retention as detailed below:
Subscribers
Data, we retain this data as long as you remain a subscriber to any service and
if you cease to be a subscriber then your data will be removed within 2 years
of ceasing to be a client, except for cases that have legal or contractual requirements
for a longer period. In most cases this will only refer to any documents/records
that HMRC require us to retain for a period of 6 years.
In
the case of non-subscribers, we retain data only as long as you wish us to, you
can remove your data at any time by using the website facility or instruct us
to do so by contacting the Company secretary. If you remove your data it will
be destroyed and it will not be possible to reclaim it or provide any record of
it. The only exception is where you have instructed us not to contact you, in
which case we have to keep a record that you do not want us to contact you.
Where
data is collected at conferences and seminars and other events arranged by or
in conjunction with the Company, the data we collect and how we will use it and
retain it will be detailed on the relevant application form. In the absence of
any such detail the following general conditions will prevail.
We
will normally collect Name, email address and interests relevant to the event.
This
detail will be made available to other attendees to enable contacts to be made
by those with similar interests.
The
details will be provided under the strict condition they are not divulged to
any party not in attendance at the event.
All
details will be destroyed by the Company within 6 months of the event unless
there is an ongoing relationship with the attendee. However it must be noted
that copies of this data will be with other members and it is possible for it
to find its way into the public domain.
E-Mails,
it is probable that copies of emails will be retained on servers in various
parts of the internet. We have no control over copies of emails that are kept
outside our control. For emails that are under our control we retain them for a
maximum period of 2 years from the date of sending unless it is necessary to
keep a copy for contractual or legal reasons, in which case they will be kept
as long as essential for that reason.
Whist no online service can be warranted 100% secure, we
work very hard to protect information about you against unauthorized access,
use, alteration, or destruction, and take reasonable measures to do so. To
enhance the security of your account, we encourage you ensure you use adequate
passwords and do not disclose them to anyone.
Where email is used as a means of communication it must be
realised that email is not a secure form of communication and you supply
personal data via email at your own risk. Therefore for changing personal data
held by us you should where possible and available use the secure forms
available on the website.
Choices
You have several choices available when it comes to information
about you:
Limit the Information that You Provide: If you are a member,
you can choose not to provide the optional information. Please keep in mind
that if you do not provide this information, certain features of our Services may
not be accessible.
Opt-Out of Electronic Communications: You may opt out of
receiving promotional messages from us. Just follow the instructions in those
messages. If you opt out of promotional messages, we may still send you other
messages, such as those about your membership and legal notices.
Set Your Browser to Reject Cookies: At this time, Company will
try and respond to "do not track" signals across all of our Services, see
further details in the cookie section. However, you can usually choose to set
your browser to remove or reject browser cookies before using the Company
websites, with the drawback that certain features of Company websites may not
function properly without the aid of cookies, typically you will not be able to
log in or utilise any forms on the website. For further information about
cookies and how they work visit www.aboutcookies.org
or www.allaboutcookies.org. For
information on how to reject cookies please refer to the documentation for the
browser you are using.
Other Things You Should Know
DO NOT TRACK
Do Not Track. This is a feature implemented
in most browsers which can be turned on by the user, sometimes called "Private
Browsing", though it is normally turned off by default and therefore requires
action to implement. If implemented a signal is sent to our servers requesting
they do not track activity, if applied this would cancel all cookies and
essentially prevent some parts of the website working.
Do Not Track requests will be honoured by
the website to the extent possible with current technical systems. There are
some items that cannot be turned off, for example the website has to track your
IP address to be able to communicate with you and those requests are kept in a
log file for a period of time. Although an IP address is considered personal
information they can and are changed and given to different people from time to
time, so an individual IP address will not exactly identify someone without access
to other information, this information is not available to us and is in general
kept by the body providing your connection to the internet. For this reason we
are not able to correlate log records containing IP addresses with any
particular person and therefore are unable to supply this data.
By exception, anyone who has been
authorised an administrator of the website will be excluded from DO NOT TRACK
as this is essential to them being able to access the administration area.
COOKIES
The Company may make limited use
of cookies on their website, but does not use cookies for tracking or analysis.
At the present time the only cookie used is the cookie _cfduid set by the
Cloudflare content distribution network, This is an essential cookie used by
Cloudflare, it cannot be disabled or refused if you wish to use the website. It
has the sole purpose of carrying out the transmission of a communication over
an electronic communications network. If any other cookies are required you
will be advised and given the option to accept or reject before they are set.
Transferring Information
Every effort is made to retain
all data within UK, however the nature of Content Distribution and Cloud Backup
and the very nature of the internet does mean that data could get retained on
servers or other storage media outside the UK, this is especially true when
accessing Services from outside the UK. We have no control over this. If you
are in UK it is likely your data will never leave the UK, but if you access
from any other country, including other EU countries it is possible your
connection can be routed over a system that takes it outside the EU. However
all connections to our website are handled over secure HTTPS links so any
access is encrypted and cannot in general be seen by any third party.
Ads and Analytics
Services Provided by Others
The Company
do not use advertising services provided by others, however some facilities on
the Company website may require the setting of cookies to function, for example
the Google Re-Captcha verification used may set a cookie as part of the
verification process and Cloudflare may set a cookie to enable content
distribution services. This as far as we are aware is not traceable to you and
does not contain any personal information.
Google Invisible reCAPTCHA is
utilised on our website as a spam protection service, use of this Invisible reCAPTCHA
is subject to the Google Privacy Policy and Terms of Use.
https://www.google.com/intl/en/policies/privacy/
https://www.google.com/intl/en/policies/terms/
Third Party Software
If you like to use third party
software like browser plugins with our Services, please keep in mind that when
you interact with them you may provide information about yourself to those
third parties. We don't own or control these third parties or the way in which
you install and implement them and they have their own rules about collection,
use and sharing of information. You should review their rules and policies when
installing and using third party software.
Website Hosting
Hosting, development and
maintenance of internet services is carried by John Steel. This privacy policy also
covers such services.
Hosting is leased from Kualo UK and thier terms, conditions and policies, available at
https://www.kualo.co.uk/terms will also apply.
Where the Company operate a web
presence on a third party platform, such as Facebook and Twitter, please refer
to their website for details of their policies.
Links to other websites
Our website may contain links to
other websites of interest. However, once you have used these links to leave
our site, you should note that we do not have any control over that other
website. Therefore, we cannot be responsible for the protection and privacy of
any information which you provide whilst visiting such sites and such sites are
not governed by this privacy statement. You should exercise caution and look at
the privacy statement applicable to the website in question.
Change Log
This is the original document issued on 15th May 2018
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