Privacy Policy for use of Primer

Chloedigital limited, hereafter referred to as “chloédigital”, are committed to protecting and respecting your privacy. In this policy, “we” and “our” means chloédigital. Below is our Privacy Policy relating to Primer, our WordPress plugin, which we want you to read carefully to understand our views and practices regarding your personal data and how we will treat it. This Privacy Policy applies only to information that we collect about you when you use Primer. Please note that this Privacy Policy does not apply to any of other of our products or services. For the purpose of the Data Protection Act 1998 (the Act), the data controller is chloédigital limited of Oakdene, Burton Lane, Goffs Oak, Hertfordshire, EN7 6SE.

By using and installing Primer, you agree to our use of your personal information as set out here. This policy provides you with information regarding:

  • Information we collect;
  • how we use your data;
  • how we ensure your privacy is maintained; and
  • your legal rights relating to your personal data.

By using Primer and agreeing to these terms, you represent that you are at least the age of majority in your place of residence.

Information We Collect

We only collect information about you if we have a reason to do so. For example, to assist the functionality of Primer, to communicate with you or to make Primer and our services better. We collect information when you provide information to us personally and automatically whilst you are using our Product.

Account Information: When you download Primer, we will ask you to provide information regarding your Blog URL, Blog Name, admin Email Address and we will also request that you upload a main image.

Log Information: We will collect information that web browsers, devices, and servers make available. This may including information such as the browser type, operating system, IP address, unique device identifiers and language preference. For more information about how you can control the use of cookies, please see our Cookie Policy outlined in our membership Privacy Policy.

Usage Information: We collect information about your usage of Primer. For example, when you post using our widget, we collect information regarding the Blog Post URL, the Main Image URL, Alternative Image URL, Product Name and Product URL. We use this information to maintain the functionality of Primer. We also use this to provide Primer updates to you and gain insights on how we can make Primer better.

Location Information: We may determine the approximate location of your device from your IP address, for example, if you upload and post an image with location information however only if you enable permissions to do so through your operating system.

How We Use Information

We use the information we collect or monitor about you to: (i) Update and maintain the functionality of Primer; (ii) Provide content and updates; (iii) Diagnose issues and provide user support;  (iv) Perform analysis on your interactions and use of Primer; (iv) Communicate with you, for example via email regarding promotions, services or know how offered by chloédigital that we think will be of interest to you. We also may request your feedback on Primer so we make improvements.

Legal Basis for Processing Information

We collect and use a user’s personal data because it is necessary for the pursuit of our legitimate interests (as set out above), the purposes of complying with our duties and exercising our rights under a contract; or complying with our legal obligations. We also rely on your consent as a legal basis for processing personal data, for example, in relation to sending direct marketing communications. Consent may be withdrawn at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

Sharing Information

We put strict measures in place that ensure that all personal information and communications will never be disclosed outside of the ways we list below. When we share your information with other organisations, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We may disclose your information in the following ways:

  1. We may disclose information about you to our employees and individuals who are our independent contractors that require access to the information to assist us in providing Primer or to process the information on our behalf.
  2. We may disclose certain personal information to strategic partners and third parties that work with chloédigital to provide products and services. We will only disclose your information to the extent necessary to allow them to perform the services they provide to us. We only allow third parties providers to access your personal information if we are satisfied they take appropriate measures to protect it. We also impose contractual obligations on service providers to ensure they can only use your personal information in the ways we outline.
  3. We may share information that has been aggregated. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.
  4. We may need to disclose the information you provide if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements. It is possible that we may need to disclose to protect the rights, property, or safety of chloédigital, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
  5. If there is a change in the ownership of chloédigital or any of our assets, we might share personal information to the new owner subject to strict confidentiality measures.

International Transfers

If we need to transfer your personal information to another organisation for processing in countries that are not listed as ‘adequate’ by the European Commission, we will only do so if we have model contracts or other appropriate safeguards in place. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. We use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed here. Your information may be transferred to, processed on and/or stored on computers located outside of your jurisdiction, for example, if you are located outside the of the United Kingdom, chloédigital may transfer data to the United Kingdom from your jurisdiction.

How Long We Keep Information

We only retain information about you for as long as necessary to fulfil the purposes outlined above. If the purposes are exhausted and we are not legally required to retain it, we will erase the information.

You’re in Control

When you provide us with your information, you are in control. If you are located within the EU, you have the following rights with respect to the handling of your personal information.

  • You have the the right to access the personal information we hold about you;
  • You have the right to request that we delete your data;
  • You have the the right to stop direct marketing messages which you can do by unsubscribing;
  • The right to request that we transfer all or elements of your data either to you or another service provide;
  • The right to complain to your data protection regulator — (the Information Commissioner’s Office).

Users outside the EU may also request explanation, correction, deletion or copies of their personal data via the email address stated within this policy. You have the right to be informed about how your personal information is being used.

RIGHT OF ACCESS: At any time, you may request access to the personal data that we hold which relates to you. You can do this by exercising a “subject access request”. This right entitles you to receive a copy of the personal data that we hold about you for correctional purposes and in order to enable you to check that we are processing that personal data lawfully. You may exercise this right by emailing us at hello@chloédigital.com making a subject access request.

RIGHT TO CORRECTION AND ERASURE: At any time, you may request that we correct personal data we hold about you which you believe is incorrect or inaccurate. Additionally, you may also request that we erase personal data. We may have a legal reason to continue processing personal data that you ask us to erase but will inform you of any reason (if applicable) when we respond to your request. You may exercise this right by emailing us at hello@chloédigital.com and stating that you are making a request to have your personal data corrected or erased and what basis you are making this request.

RIGHT TO RESTRICT PROCESSING: At any time, you may request that we stop processing your personal data, in the event for example, where we no longer need to process your personal data to provide you with our services. If we have a legal reason to continue processing personal data of which is subject to a request to restrict processing, we will provide you with an explanation forthwith. You may exercise this right by emailing us at hello@chloédigital.com and stating that you are making a request to have us stop processing the relevant aspect of your personal data and providing any details reasonably relevant to that request.

RIGHT TO TRANSFER: If you wish to transfer your data from us to a third party, you may exercise this right by emailing us at hello@chloédigital.com and stating that you are making a request to transfer your personal data to a third party.

RIGHT TO STOP RECEIVING COMMUNICATIONS:You may opt-out of receiving most e-mails from us by following the “unsubscribe” instructions provided in the e-mails. Alternatively, you may contact us as described herein. Please note that you may be unable to opt out of all emails (for example, administrative, legal or billing communications).

CONTACT OUR DATA PRIVACY TEAM: If you have an enquiry or concern about the contents of our Privacy Policy or our handling and use of your data, please email us at hello@chloédigital.com. If you are not satisfied with our response to your enquiry or concern, you may wish to contact the Information Commissioner via their website.

Changes to this Privacy Policy

chloédigital may change this Privacy Policy from time to time. We strongly encourage you to visit this page for any changes to this Privacy Policy and keep yourself informed of our practices. Your continued use of Primer following a revision to our Privacy Policy will be subject to the updated policy.

This Privacy Policy was last modified in November 2018.