Privacy Policy
This policy (together with our Terms of Use and Anti-Spam Policy, our Cookie Policy and any other documents that they refer to) sets out:
- details of the personal information that we may collect from you;
- information about how we use your personal information;
- information about the limited way we share your information with our partners;
- information about how we store your information; and
- information about your rights.
Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
Who is this policy addressed to?
For the purpose of data protection legislation including the EU General Data Protection Regulation (‘GDPR’), the data controller of your personal data is Dr. Julia Dressler, details see imprint).
When we refer in this policy to ‘you’, we are referring to a customer of our services, or a person visiting our website. We are not referring to a person receiving an email sent by a customer using our service, or a person on a mailing list maintained by one of our customers. We refer to those people in this policy as ‘Contacts’. We do not have any relationship with Contacts, and process information relating to them solely for the purposes of providing our service to our customers. When we refer to a ‘marketing list’ in this policy, we are referring to details of Contacts (including their email addresses) processed by us on your behalf to provide you with our knitting.today service.
If you are a Contact and wish to cease receiving emails from one of our customers, please unsubscribe directly using the unsubscribe link in the customer’s email message, or contact the customer directly.
If a Contact makes a direct request to be removed from the marketing list of one of our customers, we may do so on behalf of our customer, while providing notice to the customer of the Contact’s request. Our customer is the data controller in respect of Contacts’ personal data, and Contacts should consult our customer’s own Privacy Policy for details on the customer’s data protection practices. We will never use and disclose the Contact email addresses to send our own informational and promotional content. We may conduct analysis on the events (such as bounces, unsubscribes, clicks, and opens) arising from emails sent using our service this will never be in relation to a specific Contact. It will always be on an aggregated and anonymised basis, which does not identify any individual Contact.
Information we may collect from you
We may collect and process the following data about you:
- Information that you provide to us. You may give us your information by filling in forms on our website or by corresponding with us by email, live chat, phone or otherwise. This includes information you provide when you register to use our service, respond to any surveys that we send to you to complete, and when you contact us for any reason. When you register for our service we will collect your username, email, password, your business category, AWS access keys and your IP address. If you contact us, we may keep a record of any information contained in the correspondence.
- With regard to each of your visits to our website, we will collect your IP address. This information is used for fraud and abuse detection.
- We also collect data from you for the purposes of retargeting – see the ‘Retargeting’ section below.
- Payment information
When using our paid service, you will be asked for financial details such as credit/debit card information. The processing of these payments is carried out by our payment processors, Stripe an d Paypal. We do not store any credit or debit card information on our servers.
How we use your personal information
We use information held about you for the following purposes:
- to provide you with information or services that you request from us, including responding to any requests for assistance with the service;
- to send you newsletters about our service and notify you about any changes to the service;
- to carry out our obligations arising from any contracts entered into between you and us;
- to administer our site and for internal operations, including troubleshooting;
- to help optimise and develop our service, for example through statistical analysis and research on your use of our service;
- as part of our efforts to keep our website safe and secure and to monitor actual or suspected fraudulent activity;
- and to carry out retargeting advertising (see “Retargeting” section below).
Retargeting
Our website uses retargeted advertising provided by Facebook and Google. As a result of this retargeting, you may see ads for our services on other sites such as Facebook. This happens in one of two ways:
One way is that our retargeting provider will read a cookie that is already in your browser, or they will place an anonymous cookie or ‘pixel’ in your browser when you visit our site. This can only happen if your browser is set to let it happen – you can control your settings in your browser to stop this.
The other method of retargeting is to use your email address to match knitting.today ads to you when you browse other sites. This involves us sharing your email address with Facebook and Google. This form of retargeting is generally used to update you on new functionality added to the EmailOctopus platform.
Conversely, we also use Facebook to ensure that we don’t present someknitting.today ads to our existing customers. Again, this involves our sharing your email address with Facebook.
Cookies
Our website uses cookies to distinguish you from other users of our website. The majority of these cookies are required to provide our service, ensuring you remain logged in to EmailOctopus and that we can personalise the service offered. Cookies (or ‘pixels’ which are similar tracking mechanisms) are also used for retargeting purposes (see the “Retargeting” section above). Please see our Cookie Policy for full details on our use of cookies.
Where we store your personal data
The account details and IP address that we collect from you are stored on our AWS servers in Ireland, inside the European Economic Area (“EEA”). All the personal data we collect from you may be processed by our staff, or those of our service providers (See our List of Service Providers)operating outside the EEA. Such staff may be engaged in, among other things, the fulfilment of your services, and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Security
All information you provide to us is stored on our secure servers. Any payment transactions will be carried out by Stripe over encrypted connections using SSL technology (see the “Payment Information” section above). Where we have given you (or where you have chosen) a password or API key which enables you to access certain parts of our site, or you have invited team members to access parts of our site, you are responsible for keeping this password or API key confidential.
We take security very seriously, and ‘privacy by design’ is baked into our engineering and product development principles but as with any online service, despite our use of leading security tools and techniques, the personal data we hold about you can never be 100% immune from unauthorised access.
Disclosure of your information
We may disclose your personal information to any company under the same ownership as us.
We may disclose your personal information to selected third parties, including:
- in the event that we sell or buy any business or assets, the prospective seller or buyer of such business or asset;
- if knitting.today or substantially all of its assets are acquired by a third party, to the relevant third party;
- business parties and subcontractors for the purposes of providing the EmailOctopus services (please see our current List of Service Providers, available here);
- analytics providers that assist us in the improvement and optimisation of our website; and
- law enforcement agencies or regulatory bodies; or other third parties for fraud detection and prevention. We will only do this is if we are legally required to do so.
- We may also disclose your personal information to third parties 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 Anti-Spam Policy and other agreements, or to protect the rights, property, or safety of EmailOctopus, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud detection and protection and credit risk reduction.
Retention of your Personal Information
The periods for which we keep your information depend on why your information was collected and what we use it for. We will not keep your personal information for longer than necessary for our business purposes or for legal requirements.
Some account information will be held for 7 years from your last sign in or use of the service. Logs of your use of the services will be deleted within 12 months of your last sign in or use of the service.
We will keep your contact information, emails and lists for 12 months after your last sign in or use of the service, in case you decide to use our services again. We may contact you about our services during this time (unless you have asked us not to contact you for marketing purposes).
Legal basis for processing
We are required to state the legal basis on which we undertake processing of your personal information. We will only use your information where:
- We have your consent to do so; or
- We need to process the personal information to perform services for you under our terms and conditions of service.
- We have a legitimate interest in engaging in the provision of our EmailOctopus service and in offering products and services of value to you.
Any consent you provide may be withdrawn at any time by emailing us.
Your rights
You have the right to request access to personal data that we may process about you.
You have the right to require us to correct any inaccuracies in your data, free of charge. If you wish to exercise this right, you should:
- put your request in an email to us;
- provide us with enough information to identify you (e.g. username or email address); and
- specify the information that is incorrect and what it should be replaced with.
You can access, correct, update or request deletion of your personal information at any time, either through your online account or by contacting us.
Deletion of data will be carried out on the understanding that removal of some information (e.g. email address) during an active membership term may negatively affect your ability to use the knitting.today service.
We cannot delete any invoices, as these are kept for tax purposes.
You can request that we restrict processing of your personal information, object to processing of your information or request portability of your personal information. For these requests please contact us. We will comply with your request where your rights have been exercised in accordance with applicable laws.
If we have collected and processed your personal information with your consent, then you can withdraw that consent at any time. To be clear, we may still continue to process your data if we have a different legal basis for doing so (for example, if we are required by law to do so, or we need to do so for the purposes of fulfilling our obligations to you under our terms and conditions of service).
You also have the right to ask us to stop processing your personal data for direct marketing purposes. You can do this through your knitting.todays dashboard or via email. If you wish to exercise this right via email, you should:
- put your request in writing (an email with a header that says ‘Unsubscribe’ is acceptable);
- provide us with enough information to identify you (e.g email address); and
- if your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g., email or telephone), please specify the channel you are objecting to.
Changes to privacy policy
We keep our privacy policy under regular review. If we change our privacy policy we will post the changes on this page, notify you, and place notices on other areas of the site, so that you may be aware of the information we collect and how we use it at all times.
Complaints
If you have any questions or comments regarding our use of your data, please contact us by email. If you make a complaint to us and think we have not dealt with it to your satisfaction, you may send your complaint to the Information Commissioner for investigation. For more information on the Information Commissioner, and how to make a complaint, please visit their website.
Our contact details
We welcome your feedback and questions. If you wish to contact us, please send an email to support@knitting.today.