Privacy Statement (UK)


1. Introduction

 

We are committed to safeguarding the privacy of our website visitors and service users.

This policy applies where we are acting as a data controller regarding the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

We will ask you to consent to our use of cookies under the terms of this policy when you first visit our website.

In this policy, “we”, “us” and “our” refer to WARRIORBITS LIMITED. For more information about us, see Section 17.

In this privacy statement, we explain what we do with the data we obtain about you via https://myroomismyoffice.com. We recommend you carefully read this statement. In our processing we comply with the requirements of privacy legislation. That means, among other things, that:

  • we clearly state the purposes for which we process personal data. We do this by means of this privacy statement;
  • we aim to limit our collection of personal data to only the personal data required for legitimate purposes;
  • we first request your explicit consent to process your personal data in cases requiring your consent;
  • we take appropriate security measures to protect your personal data and also require this from parties that process personal data on our behalf;
  • we respect your right to access your personal data or have it corrected or deleted, at your request.

If you have any questions, or want to know exactly what data we keep of you, please contact us.

 

2. Purpose, data and retention period

 

2.1. Correspondence data (Contact Form)

 

Data collected

  • Name
  • Email address
  • IP.

The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

Please do not supply any other person’s personal data to us.  If you provide us with additional data, this is done voluntarily.

 

Purpose

Your data will be processed to enable us to contact you, to process your request and to provide you with our respective services, to prevent misuse of the contact form and to ensure the security of our information technology systems.

The legal basis is Article 6(1)(b) GDPR (Contract).

The correspondence data may be processed for the purposes of communicating with you and, if necessary, for:

  1. the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
  2. the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

 

Retention period

We determine the retention period according to fixed objective criteria: We keep your data for the period necessary to fulfill the purposes for which it has been collected. Please keep in mind that in certain cases a longer retention period may be required or permitted by law. The criteria used to determine our retention periods include: Are we subject to a legal, contractual, or similar obligation to retain your data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation, or protection against a possible claim.

 

2.1. Publication Data (Comment section)

 

Data collected

  • Name
  • Email address
  • IP.

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Please do not supply any other person’s personal data to us, unless we prompt you to do so.

 

Purpose

The publication data is processed for the purposes of enabling such publication, avoid spam to our website and, if necessary, for:

  1. the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  2. the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

 

We may process information that you provide to us for the purpose of subscribing to our email notifications when someone reply to a comment that you left on our website. The notification data may be processed for the purpose of sending you the relevant notification. The legal basis for this processing is consent.

You can opt-out of email notifications at any time by clicking on the link “Click here to stop receiving these messages” in your email or emailing us at stefan@myroomismyoffice.com.

 

Retention period

If you leave a comment on Our Site, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

You can opt-out of email notifications at any time by clicking on the link “Click here to stop receiving these messages

 

2.5 Newsletters

 

Collected data: email address, and IP.

On our website, you have the possibility to subscribe to our newsletter, in which we regularly inform you about new posts.

In addition, we store the respective IP addresses and the times of your registration and confirmation. The purpose of this method is to furnish proof of your registration and, if necessary, to be able to investigate a possible misuse of your personal data. The legal basis is Article 6(1)(f) GDPR.

The only mandatory piece of information required for the newsletter to be sent to you is your e-mail address. After your confirmation, we will store your e-mail address for the purpose of delivering the newsletter to you. We store your e-mail address with your consent. The legal basis for this is Article 6(1)(a) GDPR.

You can withdraw your consent for the newsletter at any time and unsubscribe the newsletter. You can withdraw your consent by clicking on the link provided in each newsletter, or by sending an e-mail to stefan@myroomismyoffice.com or a message to the above-mentioned contact details. As a result of the withdrawal of your consent, the data collected during registration will be deleted.

 

 

3. Providing your personal data to others

 

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

4. Cookies

 

To provide the best experiences, we and our partners use technologies like cookies to store and/or access device information.

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.

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.

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.

Consenting to these technologies will allow us and our partners to process personal data such as browsing behaviour or unique IDs on this site. Not consenting or withdrawing consent, may adversely affect certain features and functions.

Our website uses the following types of cookies, the function of which is explained further below:

 

Functional cookies

 

Technical or functional cookies

Some cookies ensure that certain parts of the website work properly and that your user preferences remain known. By placing functional cookies, we make it easier for you to visit our website.

The use of strictly necessary cookies on our website is possible without your consent. For this reason, strictly necessary cookies cannot be activated or deactivated individually. However, you can generally deactivate cookies in your browser at any time (see below).

The legal basis for the temporary storage of the data is Article 6(1)(f) GDPR.

 

Analytical cookies

 

We use analytical cookies to optimize the website experience for our users. With analytical cookies, we get insights in the usage of our website. We ask your permission to place analytical cookies.

  • Data collected: see “Data Collected by Google Analytics“. Data may include your geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
  • Legal basis: Article 6 (1)(f) GDPR.
  • Storage period: up to 60 days

This website uses Google Analytics with the extension that anonymises IP addresses. As a result, your IP address will be truncated before being sent to Google, thus ruling out the identification of the user. Therefore, where the data collected about you contain any reference to persons, such reference will be immediately excluded. For those exceptional cases in which personal data are transferred to the USA, Google is subject to the EU-U.S. Privacy Shield.

You can prevent data generated by the cookie and relating to your use of the website (including your IP address) from being collected and processed by Google, by downloading and installing this browser plug-in.

If you are visiting our website on a mobile device (e.g. smartphone or tablet), you can prevent data collection by Google Analytics by visiting our Cookie Policy, where you can opt out of statistics cookies.

 

Marketing/Advertising Cookies

 

Marketing/Tracking cookies are cookies or any other form of local storage, used to create user profiles to display advertising or to track the user on this website or across several websites for similar marketing purposes.

Because these cookies are marked as tracking cookies, we ask your permission to place these.

We use Google Ads for advertising.

Privacy Statement from Google Ads is available here.

The legal basis for the temporary storage of the data is Article 6(1)(f) GDPR.

 

IAB Europe Transparency & Consent Framework

 

Warriorbits Limited participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. It uses the Consent Management Platform with the identification number 332.

We have concluded a data Processing Agreement with Google.

Google may not use the data for any other Google services.

The inclusion of full IP addresses is blocked by us.

 

How to Manage Cookies

 

Please consult our Cookie Policy for more information about the type of cookies and tracking technologies we use on this Website and how to accept and reject them.

 

5. Who else can access your personal data?

 

We use external service providers to support us in the operation of our website. These have been carefully selected and commissioned by us, are bound to our instructions, and are controlled regularly.

We only work with Processing partners who are able to ensure an adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so.

This collaboration is based on data processor agreements in accordance with Article 28 GDPR. As a rule, these external service providers who provide us with technical support (e.g. web hosters, programmers) have at least the possibility to access personal data. Such access is not intentional. However, we cannot rule out in individual cases that certain personal data are disclosed to these providers as part of their activity. From a data protection point of view, these are so-called recipients (Article 4(9) GDPR) of personal data.

We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or for all the reasons outlined in section 3.

Our current processing partners are:

 

 Knownhost LLC

 

  • County: United States
  • Purpose: Our hosting facility is considered a processor in regards to your personal data.
  • Data collected: Knownhost LLC has no control over how the data is acquired, stored, or processed. Besides, it will never copy or use data for any purpose.
  • Legal basis: Article 6 (1)(f) GDPR.

 

proinity LLC (KeyCDN)

 

  • Country: Switzerland
  • Purpose: CDN (Content Delivery Network) is a highly distributed platform of servers that helps minimize delays in loading web page content by reducing the physical distance between the server and the user. KeyCDN allows us to gather visitor log information for the purpose of analyzing, testing, and troubleshooting.
  • Data collected: Your IP addresses is anonymized within the content delivery logs provided. Furthermore, statistical data is aggregated and does not contain any personal data.
  • Legal basis: Article 6 (1)(f) GDPR.

 

Defiant (Wordfence)

 

  • Country: United States
  • Purpose: This website uses the Wordfence plug-in to protect from viruses and malware, and for defence against external attacks. Wordfence Security verifies the visits to the website as to their legitimacy and logs the visits to the web hosting server in the same extent as the latter.
  • Data collected: IP addresses are stored on the Wordfence servers in the USA for the purpose of protection against brute-force and DDoS attacks or comment spam. IP addresses classified as safe are put on a white list.
  • Legal basis: Article 6 (1)(f) GDPR.

 

 

6. International transfers of your personal data

 

In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

The hosting facilities for our website are situated in the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

 

7. Retaining and deleting personal data

 

This Section 6 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 data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

(a) Any personal information received by My Room is My Office will be retained for a minimum period of 1 month following the date the data was received, and for a maximum period of 2 years following the date the data was received.

In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

A maximum of 2 years for any personal information received by My Room is My Office will be determined based on the purposes of usability of data and the purpose of retaining the data.

Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

8. Security of personal data

 

We will take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks.

We will store all your personal data on secure servers.

Even though we try our best, we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

 

9. Amendments

 

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of changes to this policy by email.

 

10. Your rights

 

In Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

9.1    Your principal rights under the data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)     the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

9.2    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

9.3    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

9.4    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

9.5    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

9.6    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

9.7    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

9.8    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

9.9  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

9.10  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

9.11  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.12  You may exercise any of your rights in relation to your personal data by sending an email to stefan@myoomismyoffice.com.

 

11. Third party websites

 

10.1  Our website includes hyperlinks to, and details of, third party websites.

10.2 These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

10.3  We have no control over, and are not responsible for, the privacy policies and practices of third parties.

 

12. Personal data of children

 

Our website and services are targeted at persons over the age of 18.

If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

 

 

13. Data Protection Authority – Contact Information

 

The local supervisory data protection authority in the UK is the ICO. (Information Commissioner’s Office).

Website: https://ico.org.uk

Email:

scotland@ico.org.uk (Scotland)

wales@ico.org.uk (Wales)

ni@ico.org.uk (Northern Ireland)

Phone:

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number

Fax: 01625 524 510

 

14. Our details

 

This website is owned and operated by WARRIORBITS LIMITED.

We are registered in England under registration number 11365116, and our registered office is at:

71-75, Shelton Street

Covent Garden

London

WC2H 9JQ

ENGLAND

 

You can contact us:

(a)    using our website contact form; or

(b)    by email, using stefan@myroomismyoffice.com