Legal | Winstonjgreene

Updated: Oct 4, 2018

PRIVACY

This is the privacy policy (“policy”) for www.winstonjgreene.com, which is run and provided by Winston J. Greene Academic Services, 50 Kauri Street, 9022 Dunedin, New Zealand (we, us, and our).
We will only use the personal data gathered over this website as set out in this policy. Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.

I. Summary of our processing activities

The following summary provides you with a quick overview of the processing activities that are undertaken on our website. You will find more detailed information under the indicated sections below.
   •   When you visit our website for informational reasons without setting up an account, only limited personal data will be processed to provide you with the website itself (see III).
   •   In case you contact us, register for the website, subscribe to our newsletter, or purchase services further personal data will be processed in the scope of such services (see IV, V, VI, and VII).
   •   Furthermore, your personal data will be used for statistical analysis that helps us to improve our website (see IX). Additionally, we improve your website experience with links to third party content (see X).
   •   Your personal data may be disclosed to third parties (see XI) that might be located outside your country of residence; potentially, different data protection standards may apply (see XII).
   •   We have implemented appropriate safeguards to secure your personal data (see XIII) and retain your personal data only as long as necessary (see XIV).
   •   Under the legislation applicable to you, you may be entitled to exercise certain rights with regard to the processing of your personal data (see XV).

II. Definitions

Personal data: means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier. Processing: means any operation which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation, or any kind of disclosure or other use.

III. Informational use of the website

When you visit our website for informational reasons, i.e. without registering for any of our provided services listed under IV and without providing us with personal data in any other form, we may automatically collect additional information about you which will contain personal data only in limited cases and which is automatically recognised by our server, such as: * Your IP address * the website from which you have been directed to our site * the date and time of your requests * your device type, screen resolution, and browser version * your internet service provider * information on your operating system, including language settings * information on the offers you have visited on our website.
We use such information only to assist us in providing an effective service (e.g. to adapt our website to the needs of your device or to allow you to log in to our website), and to collect broad demographic information for anonymised, aggregated use. The personal data automatically collected is necessary for us to provide the website, Article 6 sec. 1 sent. 1 lit. b GDPR, and for our legitimate interest to guarantee the website’s stability and security, Article 6 sec. 1 sent. 1 lit. f GDPR.

IV. Request

You may contact us without registering for an account. Whenever you contact us via the channels provided on the website (email or in writing) we will store the personal data you provide. These may contain: * Name and address (including title) * Email address * Phone number * Company and organization type * Occupation and/or area of interest * Country the company/organization is located in.
For this, the legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR and for our legitimate interest to utilize customer communication as examples to improve our customer service team, Article 6 sec. 1 sent. 1 lit. f GDPR.
The information you provide when contacting us (see also section ) will be processed to: * Communicate with you * Provide you with the services and information which you request * Improve our customer service.
This information will be archived for later reference, and we will utilize the communications to improve our customer service. We will restrict the processing of the respective information in accordance with statutory retention requirements.

V. Registration for our services

Our website offers services for purchase. In order to purchase services, you have to provide personal data. With regard to the registration of an account and its subsequent use, we process: * Name * Email address * Country * Your subject.
The above information is necessary for the performance of the service and is labeled accordingly. All further information is provided voluntarily. This information is optional and helps us provide you with better service. It also may be deleted at any time by visiting your account page and making the space blank. We will process the personal data you provide to: * Manage all services purchased through the website * Identify you at sign-in * Administer your account * Communicate with you about services you purchase through the website. For this, the legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR. Your personal data is, in the absence of exceptions within the specific services mentioned below, retained for as long as your user account is used. After deletion of your account, your personal data will be erased 1 month later. Statutory storage obligations or the need for legal actions that may arise from misconduct within the services or payment problems can lead to a longer retention of your personal data. In this case, we will inform you accordingly.

VI. Information about the specific uses that require registration – Paid Services

For the use of our paid services (English Editing and other services) you have to submit your personal data and manuscript as described under V. Your customer account retains your personal data in order to communicate with you during a submission. In addition, it allows us to enable re-edits and enables you to have access to your completed submissions whenever you need them. Finally, it enables us to answer complaints by viewing the completed work. This processing is based on Article 6 sec. 1 sent. 1 lit. b.]
By statutory law we are required to retain the provided financial data in relation to transactions (including address, payment, and order information) for 10 years. Regarding this, the retention of your personal data is based on Article 6 sec. 1 sent. 1 lit. c GDPR.

VII. Newsletter and Marketing E-mail Communications

With your email address you can subscribe to our newsletter and marketing e-mail communications that provide you with the latest news about our products and services if you consent to receiving such newsletters. This also includes special offers and exclusive discounts. The legal basis for this processing is Article 6 sec. 1 sent. 1 lit. a GDPR. Your email address will be retained as long as you subscribe to marketing emails.
On the site, this service is provided by means of a double-opt-in. Thus, you will receive an email containing a link by which you can confirm that you are the owner of the email address and wish to be notified via our email service. When your subscription is not confirmed within 96 hours after the confirmation mail has been requested, the personal data you provided will not be processed for any purpose and it will be automatically erased.
You may also opt-in to our newsletter and marketing e-mail communications at account registration: * If you are from an EU country, you may opt-in to the email by checking a box at account registration to provide consent. In this case, there will not be a double-opt-in email because you are registering for an account. * If you are not from an EU country, you opt in to receive communications by signing up for a free account.
Regardless of your country, you can unsubscribe from this newsletters and marketing emails by opting out via the link provided in each newsletter or marketing email.

VIII. Automated decision making

We do not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you.

IX. Analysis

For statistical analyses we use web analytics services to collect information about the use of this site.
1. General tracking information: The tools collect information such as:
   •   Device and browser information (operating system information, Mobile device identifier, mobile operating system, etc.)
   •   IP address (shortened and anonymized)
   •   Page accessed, URL click stream (the chronological order of our internet sites you visited)
   •   Geographic location
   •   Time of visit
   •   Referring site, application, or service
We use the information we get from the providers only to determine the most useful information you are looking for, and to improve and optimise this website. We do not combine the information collected through the use of the tools with personal data.
The tools collect only the IP address assigned to you on the date you visit this site, rather than your name or any other identifying information. The provider will use this information in order to evaluate your use of the website, to compile reports on website activities and to provide other services relating to website and internet use to us.
The legal basis for this processing is Art. 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to analyse our website’s traffic to improve the user’s experience and to optimise the website in general.
2. Google Analytics / Google Tag Manager
We use Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). On our behalf Google will use the information generated by a cookie for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet activity in connection with the use of the website.
We have activated the IP-anonymisation within the Google Analytics service, and your IP address will be truncated within the area of member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. The IP-address your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google.
You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality of this website. In addition to that you may prevent the collection of the information generated by the cookie about your use of the website (including your IP address) and the processing of this data by Google if you download and install the browser plug-in available at the following link: http://tools.google.com

X. Third party content and social media plug-ins

This website may contain links to third party websites. We are not responsible for the content and the data collection on respective third party websites; please check the privacy policy of respective websites for information of respective websites’ data processing activities.

XI. Information sharing

Where personal data is disclosed to the following third parties for the purposes mentioned above the legal basis for the transfer of your personal data is Article 6 sec. 1 sent. 1 lit. b and f GDPR. Some of the recipients may reside outside the EEA. For further information about cross border transfer in general and transfers outside of the EEA see XI.

Our agents and business partners
We employ other companies and individuals to administer, service, or process customer transactions. Examples of such activities include order fulfilment, order delivery, credit card payment processing, and customer service support. It may also be necessary for us to pass your information on to the editors that we work with to proofread your documents. We may also disclose information to our business partners for their own purposes, such as performing analytics, gaining customer insights, and marketing their products and services.

Credit card companies
Credit card transactions are handled by a third-party financial institution and their vendors, which receive the credit card number and other personal identifying information such as IP address to verify the credit card numbers and process transactions.
Business reorganization/sale
In the event that we undergo re-organization or are sold to a third party (in whole or part), any personal information we hold about you may be transferred to that re-organized entity or third party subject to the terms of this Privacy Policy.

Compliance & protection
We may release your information when we believe, in our reasonable judgment, that release is appropriate to (i) protect the security and integrity of our website; (ii) protect our rights and property and the rights and property of others; (iii) take precautions against liability; (iv) comply with legal requirements or respond to judicial process; and (vii) provide information, to the extent legally permitted, to law enforcement agencies or for investigations on matters related to public safety.

XII. Cross border data transfers

Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries (including countries outside the EEA) which may have different data protection standards from your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to maintain an adequate level of data protection when sharing your personal data with such countries.

Onward Transfers
We will only transfer your personal information to third parties as set forth herein, and we will ensure that any third party to which we transfer your personal information is a part of the EU-US Privacy Shield or is subject to laws providing the same level of privacy protection as required by the EU-US Privacy Shield Principles and agrees in writing to provide an adequate level of privacy protection.

XIII. Security

We have reasonable state of the art security measures in place to protect against the loss, misuse, and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our website whilst it is in transit over the internet and any such submission is at your own risk.

XIV. Data retention

We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.

XV. Your rights

Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:
   1.   require (i) information as to whether your personal data is retained and (ii) access to and/or duplicates of your personal data retained, including the purposes of the processing, the categories of personal data concerned, and the data recipients as well as potential retention periods; 
   2.   request rectification, removal or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn; 
   3.   refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time; 
   4.   object, on grounds relating to your particular situation, that your personal data shall be subject to a processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for an ongoing processing; 
   5.   take legal actions in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators; 
   6.   require (i) to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller; and/or 
   7.   not to be subject to any automated decision making, including profiling (automatic decisions based on data processing by automatic means, for the purpose of assessing several personal aspects) which produce legal effects on you or affects you with similar significance. You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us using the contact details set out below.
 
XVI. Contacting us

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by email to info@winstonjgreene.com.
Compliance Officer 50 Kauri Street 9022 Dunedin
New Zealand Email: info@winstonjgreene.com
The information you provide when contacting us will be processed to handle your request and will be erased when your request is completed. Alternatively, we will restrict the processing of the respective information in accordance with statutory retention requirements.

XVII. Amendments to this policy

We reserve the right to change this policy from time to time by updating our website respectively. Please visit the website regularly and check our respective current privacy policy. This policy was last updated on October 4, 2018.