Last Updated: [10-10-2020]
1. Introduction
Welcome to [Your Blog Name Here] (“we,” “our,” or “us”). We are committed to protecting your privacy and being transparent about how we handle your information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you visit our website Your Website URL Here.
As our team and ownership are distributed across multiple jurisdictions, including Hong Kong, China, Thailand, Russia, Ukraine, the Philippines, and Cambodia, we strive to handle all data with a high standard of care, regardless of its origin.
By using our Site, you consent to the practices described in this policy.
2. Information We Collect
Since our blog primarily features publicly available information, our data collection is minimal.
a) Information You Voluntarily Submit:
- Comments: When you leave a comment on the Site, we collect the data shown in the comments form, your IP address, and browser user agent string to help spam detection.
- Contact Forms: If you contact us via a form, we collect your name and email address to respond to you.
- Subscription Forms: If you subscribe to our newsletter or updates, we collect your email address.
b) Information Automatically Collected:
- Log Data: Like most websites, we automatically collect information that your browser sends. This may include your IP address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
- Cookies & Tracking Technologies: We use cookies to analyze web traffic, remember your site preferences, and offer you a better experience.
c) Information from Third Parties:
We may receive data about you from third-party services like Google Analytics, which analyzes traffic to our Site.
3. How We Use Your Information
We use the information we collect for the following purposes:
- To operate, maintain, and improve the Site.
- To respond to your comments or inquiries.
- To send you promotional information, such as newsletters, if you have opted-in. Each email will provide an option to unsubscribe.
- To track and analyze trends and user behavior to improve your experience.
- To protect, investigate, and deter against unauthorized or illegal activity.
4. Legal Basis for Processing (GDPR Compliance)
For visitors from the European Economic Area (EEA), our legal basis for collecting and using your information depends on the context:
- Performance of a Contract: Fulfilling a subscription you requested.
- Legitimate Interests: Our need to operate the website, provide content, and analyze traffic in a way that does not override your rights.
- Consent: Where we have asked for and you have given clear consent (e.g., for marketing emails). You can withdraw consent at any time.
5. International Data Transfers
Given our international team, your information may be processed in countries other than your own, including Hong Kong, Thailand, the Philippines, and others where our team members are located. These countries may have data protection laws that differ from your country.
We take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Any transfers of data from the EEA to countries without an adequacy decision will be handled under appropriate safeguards, such as Standard Contractual Clauses.
6. How We Share and Disclose Your Information
We do not sell, trade, or rent your personal data to third parties. We may share information in the following limited circumstances:
- Service Providers: With trusted third-party vendors who assist us in operating our website (e.g., hosting providers, email marketing services, analytics tools). These parties are obligated to keep your information confidential.
- Legal Obligations: If required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
- Business Transfers: In connection with a merger, sale of company assets, or acquisition of all or a portion of our business.
7. Data Retention
We will retain your personal information only for as long as is necessary for the purposes set out in this policy, or as required to comply with legal obligations.
- Comment data is retained indefinitely so we can recognize and approve any follow-up comments automatically.
- Analytics data is retained for a period set by our analytics providers.
- Subscription data is retained until you unsubscribe or ask us to delete it.
8. Your Data Rights
Depending on your location, you may have the following rights regarding your personal data:
- Access: The right to request copies of your personal data.
- Rectification: The right to request that we correct any information you believe is inaccurate.
- Erasure (“Right to be Forgotten”): The right to request that we erase your personal data.
- Restrict Processing: The right to request that we restrict the processing of your personal data.
- Data Portability: The right to request that we transfer the data we have collected to another organization, or directly to you.
- Object to Processing: The right to object to our processing of your personal data.
To exercise any of these rights, please contact us using the details at the end of this policy.
9. Cookies
We use cookies to improve your experience. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
10. Children’s Privacy
Our Site is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with information, please contact us, and we will delete it.
11. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the “Last Updated” date. You are advised to review this policy periodically for any changes.
12. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact us at:
[contact@deviwillson.com]