This Privacy Policy (“Policy”) describes the information that we gather on this Site, how we use and disclose such information, and the steps we take to protect such information. By visiting the Site, or by purchasing, You accept or may be asked to read and accept the privacy practices described in this Policy. Please, read this Policy before using this Site. If You do not agree with this Policy do not use this Site and/or do not agree with this Policy when purchasing.
This Policy is incorporated into, and is subject to the Site Terms, please read it in conjunction with it.
Please note that we follow the requirements of the so-called European Union General Data Protection Regulation and other applicable data protection laws while collecting, using and storing information about You.
DEFINITIONS
“Company” INTERNET IDEAS PUBLISHING Limited” means the owner and operator of the Site.
“Site”(also referred to as "we", "us", and "ours") means the website paulmcginley.com or any sub-domains of this website (e.g. subdomain.paulmcginley.com) or other associated different domain sites, if used as a part of such website and its purposes and operated by the Company, unless expressly excluded by their own terms and conditions (also collectively the “Site”).
“GDPR” European Union General Data Protection Regulation.
“Customer” (also referred to as “You”, “your”) includes anyone who purchase products or services of this Site.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Customers and Visitors, without needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Customers, and where access requires logging in.
“Visitor” (also referred to as “You”, “your”) means a user other than a Customer, who uses the public area, but do not purchase and has no access to the Restricted area of the Site.
“Account” Customer’s personal account in the Site to access his/her purchases.
1. DETAILS AND CONTACTS OF DATA CONTROLLER
The data controller (use the GDPR provided definition) for the processing of the data of this Site is INTERNET IDEAS PUBLISHING Limited, a corporation organized and existing under the laws of the Republic of Ireland, with its head office located at 36 Main Street, Portlaoise, Co. Laois, R32 R7D5, Ireland, with Company code 587742 and VAT code IE3448615RH.
Please contact us with any questions, concerns, complaints or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by emailing us at hello@highperformers.com.
2. THE DATA WE COLLECT THROUGH THE SITE
We collect different types of information through the Site. The legal bases for the Site processing of Personal Data are primarily that the processing is necessary for providing the products and services and to meet contractual obligations, in accordance with the Site Terms and that the processing is carried out in the Site’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy.
In brief, the following personal data (categories of personal data) can be collected and processed on this Site:
- Name;
- Surname;
- Email address;
- Contact telephone number;
- IP addresses (in some cases);
- Site user’s information
- Banking details
- Address
Read more detailed explanation below:
2.1 Customer provided Information. When You use the Site, as a Customer, for example, by purchasing and registering in the Site; subscribing to newsletter; submitting the quiz/survey, You may provide, and we may collect Personal Data. Personal Data may include name, email address, mobile phone number and credit card or other billing information. You may provide us with Personal Data or other information in various ways on the Site.
2.2 Visitor information. That may include data of a Visitor who uses the public area of the website, which most of the time will be a non identifiable information. In some cases we may collect Visitor’s provided Personal Data, for example, when subscribing a newsletter, submitting the quiz/survey.
2.3 Communication information. Includes any communication that You send to us whether that be through email, text, social media messaging, social media posting or any other communication or request that You send us.
2.4 “Automatically Collected" Technical Information. When a Customer or Visitor uses the Site, we may automatically record certain information from the Customer’s or Visitor’s device by using various types of technology, including cookies. This “automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Site, the pages or other content the Customer or Visitor views or interacts with on the Site, and the dates and times of the visit, access, or use of the Site.
2.5 Marketing information. We may use data about your preferences in receiving marketing from us and our third parties and your communication preferences.
2.6 Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Site, such as our partners, advertisers, credit rating agencies. If we combine or associate information from other sources with Personal Data that we collect through the Site, we will treat the combined information as Personal Data in accordance with this Policy.
3. SENSITIVE DATA
We do not collect any Sensitive Data about You. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
4. HOW WE USE THE DATA WE COLLECT, PURPOSES AND LEGAL BASES
In brief, the specified personal data are collected and processed only in accordance with the legal grounds specified in legal acts. The above mentioned Personal Data is basically processed in accordance with these legal grounds:
- Personal Data is necessary for the fulfillment of a legal obligation (usually for financial or taxes obligations) ;
- Personal Data is necessary in order to fulfill the contract (banking details in order to pay for the services etc.);
- A data subject consent was given (example: consent to direct marketing)
- Legitimate interests of the data controller.
We use the information that we collect in a variety of ways and purposes in providing the Site and operating our business. Read more detailed explanation below:
4.1 Performance of the contract (providing the Product). We use the information and Personal Data to provide products and other services, operate the payments, register the Account, etc. Our lawful ground for this processing is the performance of a contract between You and us.
4.2 Improvements. We use the information to understand and analyze the usage trends and preferences of Visitors and Customers, to improve the Site, and to develop new products, services, feature, and functionality. Should this purpose require the Site to process Personal Data, then the data will only be used in anonymized or aggregated form.
4.3 Communications. We may use any of your communication data that includes any communication that You send to us whether that be through email, text, social media messaging, social media posting or any other communication that You send us or other information, to contact You with updates on promotions and events, relating to products and services offered by us and to answer your questions or concernings. We process this data for the purposes of communicating with You. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, or Your consent (in case of subscription to newsletters).
You have the ability to opt-out of receiving any promotional communications as described below under section “Your Rights”, but we still may use your information for other necessary communications.
4.4 Cookies, Tracking Technologies and Analytics. We may use automatically collected information and other information collected on the Site through cookies and similar technologies to: (i) personalize the Site, such as remembering a Customer’s or Visitor’s information so that the Customer or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of the Site and third-party marketing activities; (iv) monitor aggregate Site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities in the Site. We may process this data to enable You to partake in promotions such as competitions, prize draws, to deliver relevant Site content and advertisements to You and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how Visitors or Customers use the Site, the Product, to develop them, to grow our business and to decide our marketing strategy. Read more about cookies in Cookie Policy of this Site. We also use Google Analytics to measure and evaluate access to and traffic in the Site, and create navigation reports for the Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest You review. Google may use the information collected through Google Analytics to evaluate Customer’s and/or Visitor’s activity on the Site. For more information, see Google Analytics Privacy and Data Sharing. We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Customers. Our lawful ground for this processing in general is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
5. TO WHOM WE DISCLOSE INFORMATION
Except as described in this Policy, we will not intentionally disclose the Personal Data that we collect or store in the Site to third parties without the consent of the applicable Visitor or Customer. We may disclose information to third parties if You consent to us doing so by agreeing to this Policy, as well as in the following circumstances:
5.1 Service Providers. We work with third party service providers who provide website, application development, hosting, maintenance, software and other services for us. These third parties may have access to, or process Personal Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions. According to the requirements of the GDPR, we have special contracts with such third parties to ensure that they are also compliant to GDPR and respect your data at least in the same level.
5.2 Non Personally Identifiable Information. We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding Customers’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Site.
5.3 Law Enforcement, Legal Process and Compliance. We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement.
5.4 Change of Ownership. Information about Customers and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the Customer or Visitor data commits to a Privacy Policy that has terms substantially consistent with this Policy.
6. YOUR RIGHTS
Under data protection laws You have rights in relation to your Personal Data. If You wish to exercise any of the rights set out in this section “Your Rights”, please email us at hello@highperformers.com. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or You have made a number of requests.
Please Note: You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from You to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to your request to speed up our response.>
6.1 Right to Access. We respect your privacy rights and provide You with reasonable access to the Personal Data that You may have provided through your use of the Site. If You wish to access any other Personal Data we hold about You, You may contact us.
6.2 Right to data portability. You shall have the right to your Personal Data portability. If You wish request to transfer your Personal Data that we have, You may contact us.
6.3 Right to Rectification. You shall have the right to update or correct your Account information at any time by accessing your Account settings page on the Site, or any other Personal Data we hold about You by emailing to us.
6.4 Right to Erasure ("Right to be forgotten"). You shall have the right to obtain from the Site the erasure of Personal Data if the Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; or You withdraw consent on which the processing is based according to point and where there is no other legal ground for the processing; or the Personal Data have been unlawfully processed; or other legal grounds applicable.
6.5 Right to object. The GDPR right to object allows You to object to certain types of data processing and stop us from continuing to process your Personal Data. There are only certain situations when a legitimate right to object can be sent to us. These are if:
- We are processing your Personal Data for direct marketing;
- We are processing your Personal Data for statistical purposes related to historical or scientific research;
- We are processing your Personal Data for tasks in the public interest;
- Our processing is based on exercising of official authority vested in us;
- We are processing your Personal Data on ours or a third party’s legitimate interest.
6.6 Right to restrict processing
You may ask you to restrict processing your Personal Data if, for example:
- you believe your data is not accurate (we should stop processing until we verify the accuracy of the data);
- the processing is unlawful but you don't want the data to be erased
- we no longer need the data but you need it to exercise a legal claim
- we are taking steps to verify overriding grounds in the context of an erasure request
6.7 Right to complain. If You believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact hello@highperformers.com. You also have a right to lodge a complaint with data protection authorities.
6.8 Right to withdraw. You shall have the right to withdraw any consent You gave to us regarding processing of your Personal data.
You have a Right to Opt - out from commercial communications. If You receive commercial emails from us (for example subscription to newsletters), You may unsubscribe at any time. Nevertheless, even after You opt-out from receiving commercial messages from us, You may continue to receive administrative or necessary messages from us regarding the Site and services.
You have a Right to Opt - out from Cookies. You can manage your cookie preferences and to change or withdraw your cookie consent at any time, as provided in our Cookie Policy. You can also do it within your browser settings. If You block all cookies (including essential cookies) You may not be able to access all or parts of our Site or it may not function properly. You may also opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature. Read more about cookies in our Cookie Policy.
7. THIRD-PARTY SERVICES OR LINKS
The Site may contain features or links to websites and services provided by third parties. Any information You provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Site. We are not responsible for the content or privacy and security practices and policies of third-party websites or services to which links or access are provided through the Site.
8. MINORS AND CHILDREN’S PRIVACY
Protecting the privacy of young children is especially important. This Site is not directed to children under the age of 16, and we do not knowingly collect Personal Data from children under the age of 16 without obtaining verifiable parental consent. If you are under 16 years of age, then please do not use or access the Site at any time or in any manner. If we learn that Personal Data has been collected on the Site from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If You are a parent or guardian and discover that your child under 16 years of age uses the Site, then You may alert us at hello@highperformers.com and request that we delete that child’s Personal Data from our systems.
9. DATA SECURITY
We follow the GDPR requirements and generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet. We also require data security technology measures from the service providers (data processors) that we work with.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information You transmit to us or store on the Site, and You do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. However once we have received your Personal Data we use strict procedures to protect the security of your Personal Data. If You believe your Personal Data has been compromised, please contact us as set forth in the section 1.
If we learn of a security systems breach, we will inform You and the authorities of the occurrence of the breach in accordance with the GDPR and applicable laws requirements.
10. DATA RETENTION
We only retain the Personal Data collected from a Customer or a Visitor, for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it (for example as long as the Customer has an Account in the Site and a reasonable period of time after), unless otherwise required by law. We will retain and use information as necessary to comply with the legal obligations, resolve disputes, and enforce our agreements. For tax purposes the law requires us to keep basic information about Customers (including contact, identity, financial and transaction data) for six years after they stop being customers or deleted Account.
In some circumstances we may anonymise your Personal Data for research or statistical purposes in which case we may use this information indefinitely without further notice to You.
If You have a question about a specific retention period for certain types of Personal Data we process about You, please contact us using the contact details provided.
11. DATA TRANSFERS
We may work with the service providers and/or use servers outside the EU for your information or Personal Data processing. We are subject to the provisions of the General Data Protection Regulations that protect your Personal Data. Where we or our service providers might transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your Personal Data, such as:
- We may transfer your Personal Data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe;
- Where we use certain service providers who are established outside of the EEA but they are compliant to the GDPR.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
12. CHANGES AND UPDATES TO THIS POLICY
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Site. If changes are significant we will try to notify You about such changes by publishing the notice of changes in the Site or by emailing You or any other way. Changes will comply with applicable laws, including GDPR. Your continued use of the Site after the revised Policy has become effective and indicates that You have read, understood and agreed to the current version of the Policy.
© 2017 – 2022 INTERNET IDEAS PUBLISHING Limited. All rights reserved.