www.tmcaruana.com governs the privacy of its users who choose to use it.
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
1.3 All rights reserved.
(a) we, together with our licensors, own and control all the copyright and other intellectual property rights in our website and the material on our website; and
(b) all the copyright and other intellectual property rights in our website and the material on our website are reserved.
(c) you may only use our website for your own personal purposes, and you must not use our website for any other purposes.
(d) no part of content produced by T.M Caruana may be reproduced, distributed, or transmitted in any form or by any means, including photocopying, recording, or other electronic or mechanical methods, without the prior written permission, except in the case of brief quotations embodied in critical reviews and certain other noncommercial uses permitted by copyright law. For permission requests, write to the publisher at [email protected].
(e) this website may contain copyright free stock imaged allowed for commercial use. If you wish to use these pictures you must ensure you have the permission from the originator. Please read more about third party relationships in paragraph 11 in this policy.
1.5 You must not use our website in any way or take any action that causes, or may cause, damage to the website or impairment of the performance, availability or accessibility of the website.
1.6 You must not use our website in any way that is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity.
1.7 You must not use our website to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or other malicious computer software.
1.8 You must not access or otherwise interact with our website using any robot, spider or other automated means.
1.9 You must not use data collected from our website to contact individuals, companies or other persons or entities.
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3. Collecting personal information
3.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths This is compiled by analytics tools such as Mailchimp and Google Analytics);
(b) information that you provide to us when registering with our website (including your name and email address);
(c) information that you provide when completing your profile on our website (including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies);
(d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(e) information relating to any purchases you make of our goods and/or services, or any other transactions that you enter into through our website (including your name, address, telephone number, email address and card details);
(f) information that you post to our website for publication on the internet (including your user name, your profile pictures and the content of your posts);
(g) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and
(h) any other personal information that you choose to send to us.
3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
4. Using personal information
4.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(d) send you goods purchased through our website;
(e) supply to you services purchased through our website;
(f) send statements, invoices and payment reminders to you, and collect payments from you;
(g) send you non-marketing commercial communications;
(h) send you email notifications that you have specifically requested;
(i) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(j) send you marketing communications relating to our business or the businesses of carefully-selected third parties, which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(k) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(l) deal with enquiries and complaints made by or about you relating to our website;
(m) keep our website secure and prevent fraud; and
(n) verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).
4.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
4.4 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
5. Disclosing personal information
5.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, insofar as reasonably necessary for the purposes set out in this policy.
5.2 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
5.4 Except as provided in this policy, we will not provide your personal information to third parties.
6. International data transfers
6.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China and India.
6.3 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
6.4 You expressly agree to the transfers of personal information described in this Section 6.
7. Retaining personal information
7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
8. Security of personal information
8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
8.2 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.3 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you of changes to this policy by email or through newsletters via our website.
10. Your rights
10.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
10.2 We may withhold personal information that you request to the extent permitted by law.
10.3 You may instruct us at any time not to process your personal information for marketing purposes.
10.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
11. Third party websites
11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11.3 You are responsible for keeping the password you use for accessing our third party website confidential; we will not ask you for your password.
11.4 We are not liable for any complaints, disputes or financial loss you have suffered in relation to your use of a third party relationship. Your contract with other parties than www.tmcaruana.com is to be carried out at your own risk.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use both session and persistent cookies on our website.
13.5 Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
13.6 The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
Other cookies may be stored to your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
13.7 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
13.8 Blocking all cookies will have a negative impact upon the usability of many websites.
13.9 If you block cookies, you will not be able to use all the features on our website.
13.10 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
(b) in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
13.11 Deleting cookies will have a negative impact on the usability of many websites.
14. Subscription of Newsletters
14.1 This website operates an email newsletter program, used to inform subscribers about products and services supplied by this website. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.
14.2 Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties nor shared with companies / people outside of the company that operates this website.
14.3 Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list.
14.4 This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
14.5 In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.
15. Advertisement Links
15.1 This website may contain sponsored links and advertisements. These will typically be served through our advertising partners, to whom may have detailed privacy policies relating directly to the adverts they serve.
15.3 Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website. The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
16. Social Media Networks
16.1 Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively. Social Media links used on this platform is Youtube, Facebook and Twitter.
16.2 Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
16.3 This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
16.4 This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls.
16.5 Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.