Website Privacy Notice

This is the privacy notice of Second Front Media Ltd, owner of buchechaonline.com. In this document, "we", "our", or "us" refer to Second Front Media Ltd.

We are company number 9604983 registered in England.

Our registered office is at Mercury House, 19-21 Chapel Street, Marlow, SL7 3HN, United Kingdom

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Introduction

  1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
  2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
  3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
  4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
  5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
  6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
  7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes, then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1.  Information we process because we have a contractual obligation with you

When you create buy a product or service from us, so creating an account on our website, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information. The personal information we collect is limited to that which is strictly necessary for the purpose of this contract.

We may use it in order to:

  • verify your identity for security purposes
  • sell subscription membership products to you
  • provide you with our subscription membership services and support for your paid member services
  • provide you with suggestions and advice on our subscription products, subscription membership services and how to obtain the most from using our website and your user account
  • Comply with HMRC requirements for record keeping in terms of the VAT MOSS scheme for EU sales of digital service place of supply
  • Provide delivery emails directly relating to your subscription membership purchase, such as password resets, payment receipts, order confirmations, renewal information. You can opt out of receiving such emails from us at any time from the “Manage Notifications” link in the email footer, however to do so will mean that we cannot communicate with you to provide any support function or send emails relating to your transactions with us

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract. For annual subscriptions, this means up until your subscription status becomes ‘expired’.  For monthly recurring subscriptions, this means up until you cancel your subscription and your status becomes ‘cancelled’. 

2.   Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website, ask us to provide you with more information about our products and services or you submit content suggestions/questions via “Ask Buchecha” you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at buchechaonline.com using the Contact Us page. However, if you do so, you may not be able to use our website or our services further.

3.  Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

Or, to comply with HMRC requirements for record keeping for VAT or VAT MOSS schemes, including evidence of the place of supply of digital services.

This may include your personal information.

Specific uses of information you provide to us

4.  Information provided on the understanding that it will be shared with a third party

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

5.  Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it. At the point of payment, you are transferred to a secure page on the website of Stripe. That page may be branded to look like a page on our website, but it is not controlled by us.

6.  Sending a message to our support team

When you contact us, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

7.  Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Use of information we collect through automated systems when you visit our website

8.  Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our website, we ask you to agree to our cookie policy and provide a link to read further about our cookie policy, and how to prevent their use through common browser settings.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use some of the functionality of our website.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website
  • to keep you signed in our site
  • to provide the membership subscription service, using essential cookies

There is a link to our cookie policy here.

9.  Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.         

10.  Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page:

To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device setting

11.          Our use of analytics

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 14 below).

GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the analytics.js implementation of GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

Disclosure and sharing of your information

12.  Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

No such information is personally identifiable to you.

13.  Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

14. Data processing and locations – with the EU and outside of the EU

All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

Hosting – Cloudways

Our site is hosted on managed cloud hosting via secure data centres. Our data centre is in London, UK.

Email Service Provider – Elastic Email

 Elastic Email is a Canadian Company. Our transactional emails are sent out from IP pools located within the EU.

Payment Processing – Stripe

Stripe adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

If You are located in the EEA or Switzerland, Stripe comply with applicable laws to provide an adequate level of data protection for the transfer of Personal Data. Stripe is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework.

Video - Vimeo

Wordpress - Automattic Inc

Analytics - Google

Re-marketing – Facebook

Security Monitoring and Auditing

We use the WP Security Audit Log plugin as a security monitoring and auditing plugin to create a log of data about the ways that our web site is used by those who have login access to it. This information is collected and retained by the web site administrator for, as the name might suggest, security and auditing purposes.

Once activated, the plugin logs a timestamped record of when a logged-in user takes the following actions:

  1. Logs in and out;
  2. Creates, deletes or modifies or views a post (be it a page, post or a post with a custom type);
  3. Creates, deletes or modifies tags;
  4. Creates, modifies, deletes, or approves comments;
  5. Creates, modifies or deletes widgets and menus;
  6. Creates, modifies (this including changing the password), deletes a user or views another users’ profile;
  7. Installs, activates, deactivates, or uninstalls a theme or plugin;
  8. Changes system settings such as reading, general, or permalinks;
  1. (remove as applicable) Takes actions on a multisite network such as creating a new site, creating a new user on the network, adding a user to a site, changing its role, etc;
  2. Takes actions on a WooCommerce installation such as creating a new product, changing store settings, modifying the product, etc.

The timestamped record includes the following information:

  1. The user’s login name
  2. The user’s actual name as entered when their account was set up
  3. The user’s WordPress role (Author, editor, etc)
  4. The IP address from which the user accessed the site
  5. The time and date of each action detailed above while the user was logged in.

The data captured by the WP Security Audit Log plugin is stored by the web site administrator solely for security and auditing purposes.

Information captured by WP Security Audit Log is accessed only by the administrators of the web site and is stored on the web site’s database.

Information captured by the WP Security Audit Log is not shared with third parties except in the case of law enforcement requests.

Access to your own information

15.  Access to your personal information

  • At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
  • To obtain a copy of any information that is not provided on our website you may send us a request via the Contact Us page on our website.
  • After receiving the request, we will tell you when we expect to provide you with the information.

16.  Removal or obtaining a copy of your information

If you wish us to remove personally identifiable information from our website, or you wish to obtain a copy of such information you may contact us via the Contact Us page on our website.

This may limit the service we can provide to you and does not include any information that we are obliged to keep for administrative, legal or security purposes. 

17.  Verification of your information

When we receive any request to access, copy, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

18. Use of site by children

  • We do not sell products or provide services for purchase by children, nor do we market to children.
  • If you are under 18 and over 13, you may use our website only with consent from a parent or guardian and the minimum age to purchase a membership subscription is 18.
  • Our Service does not address anyone under the age of 13 ("Children").
  • We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please get in touch via our Contact Us page on the website. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

19. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

20.  What happens if our business changes hands?

19.1      We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

19.2      In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

21.  How you can complain

  • If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Please use our Contact Us page on the website.
  • If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/

22.  Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

  • to provide you with the services you have requested.
  • to comply with other law, including for the period demanded by our tax authorities;
  • to support a claim or defence in court.

23.   Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

24. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us, using the Contact Us page on our website.