Privacy Policy

1. SCOPE

This Privacy Policy explains how, why and when we collect, process and use the personally identifiable information (also referred to as simply “information” or “data”) about users of our Services (meaning you).
When we say “we”, “us” or “our”, we are referring to The Tom Sawyer Effect Limited, a company registered in England and Wales with company number 06955858. Our registered address is 7 Spectrum Court, Manor Gardens, London, United Kingdom N7 6ER.
By “Personally identifiable information” we mean any information that may identify an individual personally, such as name, email address, phone number and so on.
By “Services” we mean any services that we offer, including our website located at www.tseffect.com (the “Site”) and communication sent to you via email or instant messaging.
This Privacy Policy applies to all users, and to all the data that we collect through our Services, irrespective of the type of Services or the devices and platforms you use to access these. By using these Services, you are accepting the practices described in this Privacy Policy and you are consenting to our processing of your information as described below.


2. WHAT INFORMATION WE COLLECT FROM YOU

When you visit our Site or use our Services, we collect personal data. The information we collect about you depends on the services that you use, and how you use them:
Information you provide to us directly: You do not have to give us any personal information in order to use our Site. However, when you use the contact form on our website, we ask you to provide your name, email address and the nature of your request, which helps us collect the information we need to categorise your question and appropriately respond to it. When you sign up to receive email or instant message communications from us, we will only ask for your email address, name and telephone number.
Information we collect automatically: We collect some information about you automatically when you use our Services. For example, we collect information about how often you use our Services, pages visited, links clicked, mouse movements, and other information about how you interact with our Site. We may also collect data about how you interact with messages we send to you, for example whether you opened an email or read a social media message. We collect information about the device you use to access our Services, including your browser, operating system, and cookie information, and we may also collect your location data, as indicated by the Internet Protocol (IP) address you use to access our Services. This information is aggregated and is not used to identify you.
Information we get from third parties: We may also obtain information from our third-party partners and service providers, to analyse how our users make use of our Services. We use this aggregated information to better understand and optimise our Services, which we’re constantly working on improving.
This means we are introducing new features for our services regularly, some of which may result in the collection of new data from you. We only collect personal information that is reasonable or necessary to deliver information, products, or services that you have specifically requested or required by law.
You may choose not to provide this information, but you need to understand that in some circumstances this may mean we are unable to provide you with a certain service or product. Any personal information provided by you as a user of the Services will be used only as described in this Privacy Policy.

 

3. HOW WE USE YOUR PERSONAL INFORMATION

We use, process, and store your personal information as necessary to provide you with any services you’ve requested, and to manage our relationship with you, including:
• Providing the services you have ordered;
• Communicating with you via email, or other means available on or through the Services;
• Marketing to you: we may send marketing emails and special offers from The Tom Sawyer Effect, from which you can unsubscribe at any time; we may also use your personal data to display targeted advertising to you online (through our Services or through third-party websites and platforms);
• Administering our Site and providing support to you, such as responding to your requests for assistance or information;
• Gathering management information to form statistical and trend analysis;
• Investigating any complaints about our services or this Site;
• Personalising your experience of this Site; and
• Contacting you about our products and services that we think might be of interest to you (where we have the appropriate permissions to do so).
You can opt out of receiving our communications in the footer of each email we send to you or by contacting us directly via privacy@tseffect.com.


4. HOW WE SHARE YOUR PERSONAL INFORMATION

We will only disclose your personal data to:
Third party service providers who assist us in meeting business operations needs, including hosting, delivering, and improving our Services. We use service providers for specific services and functions, including email communication, maintenance, customer support services, instant messaging communication, file storage or task management. We may also share your data with analytics and search engine providers that assist us in trend analysis, broad demographic information gathering, and the improvement of our Services. These service providers may only access, process, or store personal data pursuant to our instructions and to perform their duties to us.
Regulators, government agencies, law enforcement bodies, courts or other third parties where we believe it’s necessary to comply with applicable laws or regulations or to exercise, establish or defend our legal rights.
Other third parties where we have your explicit consent to share your personal data.


5. TRANSFER OF YOUR PERSONAL INFORMATION OUTSIDE THE EEA

Your data may be transferred to, and processed in, countries other than the country you live in – such as to the United States, where some of our service providers’ servers are located. That country may not provide the same level of data protection as the UK. Whenever we transfer your information outside of the European Economic Area, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely. By submitting your personal information to this website, you consent to such transfers taking place.


6. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies to collect information about your activity across our Services. A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a website’s computers and stored on your computer’s hard drive.
We use the following types of cookies across our Services:
Performance Cookies: These cookies collect anonymous information on how you use our Site. For example, we use Google Analytics to help us understand how you arrive at our Site, browse or use our Site and define areas of improvement such as navigation, user experience or marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
Functionality Cookies: These cookies remember choices you make, such as the country you visit our website from. These can then be used to provide you with better tailored experience. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting Cookies or Advertising Cookies: These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an online advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers.
Social Media Cookies: These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site. To find out more about cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy.


7. DATA STORAGE AND SECURITY

We’re committed to protecting your personal data and have implemented reasonable measures to prevent unauthorised access to our servers, and to safeguard data. We have implemented such technology and security features ourselves or purchased them from specialised third parties, and we maintain strict internal guidelines to safeguard the privacy of your personal information from unauthorised access or improper use. Backups are run to prevent loss of information, and we will continue to enhance security as new technology becomes available. We encrypt our services using secure sockets layer (SSL) and/or transport layer security (TLS). Please note that despite these measures, no website can guarantee data to be 100% secure.


8. LINKS

Our site contains links to other websites over which we have no control whatsoever. We will not be responsible for privacy policies or practices of other websites to which you choose to link from this site. We encourage you to review the privacy policies of these respective websites, so that you can understand how they collect, use and share your personal information.


9. SALE OF THE BUSINESS

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.


10. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

You have certain rights in respect to your personal information, including the right to access, correct, or delete personal data we hold about you.
In this sense, you can:
Request access to the data that we have about you. You can request it by sending an email to privacy@tseffect.com. Please note that we may request additional information from you to verify your identity before we disclose any information.
Have your personal data corrected or deleted. You can request for your personal data to be corrected or removed by emailing privacy@tseffect.com.
Object to our continued processing of your personal data. You can ask us to stop using your personal data, including when we use your personal data to send you marketing emails. You can opt out of receiving marketing communications at any time by clicking the “unsubscribe” link found within our emails.
If you have any questions or concerns regarding privacy when using our Services, please send us a detailed message to privacy@tseffect.com. If you’re based in the European Economic Area and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.


11. CHANGES TO OUR PRIVACY POLICY

We may change this Policy every now and then, so do please check this page occasionally to ensure that you’re happy with any changes. We will notify you about significant changes in the way we treat any personal information, by sending a notice to your email address or by placing a prominent notice on our Site. By using our Site and Services, you’re agreeing to be bound by this Policy.
We last updated this document on May 18th 2018.


12. HOW TO CONTACT US

If you have any questions about this policy, or your personal information, please get in touch with us via privacy@tseffect.com.

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