Thank you for choosing to be part of The Cynic community at 90 Minute Cynic Limited, trading as The Cynic (“The Cynic”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy.
The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website or mobile app (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of our services, including any data you may provide through this website when you sign up to our newsletter, purchase a product, contact us, take part in a service or enter into discussion on our site.
Our services are not intended for children and we do not knowingly collect data relating to children. Regulating the use of the Site and App by those under the age of 16 is the responsibility of the parent or guardian.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
90 Minute Cynic Limited is the controller and responsible for your personal data (collectively referred to as The 90 Minute Cynic, “we”, “us” or “our” in this privacy notice. Our business contact details are JWD Accounting And Tax Services, 14/2 Hermand Terrace, Edinburgh, Scotland, EH11 1QZ | email@example.com . For all data matters contact The Cynic at firstname.lastname@example.org.
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
The personal information that we collect depends on the context of your interactions with us, our services or apps, the choices you make and the products and features you use.
We may collect, use, store and transfer different kinds of personal data about you, and given voluntarily by you, which we have grouped together follows:
- Identity Data includes first name, last name, username, title, date of birth.
- Contact Data includes billing address, delivery address, email address, telephone numbers.
- Credentials includes passwords, passwords hints and authentication data.
- Payment Data including credit or debit card information, purchase history, invoices and other financial information.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or mobile application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
If you fail to provide personal data
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
Information Provided by You
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- Create an account;
- Subscribe to our service or publications;
- Contact us about our services;
- Request marketing to be sent to you.
Information that we collect through your use of our website
- Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Services or Apps, and for our internal analytics and reporting purposes. For more information on our data collection in this regard please see: https://thecynic.co/cookie-policy.
Information we collect through our Apps
We may collect information via our mobile apps. If you use our Apps, we may also collect the following information:
Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
InApp Purchases. Should you purchase services via InApp subscription we may collect data from you via the service provider.
Information that we collect from other sources
We may collect information from our users that we collect from other sources or public sources, including such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links). We will inform you about the source of information and the type of information and the type of information we have collected about you within a reasonable period after obtaining the personal data, but at the latest within one month.
When you post information on a discussion board or comment publically on an article on our Site, this information and your username will be publically accessible. This information can be viewed online and collected by other people. We are not responsible for the way in which others use this information. When contributing to a discussion or leaving a comment, we strongly avoid sharing personal details especially that which can be used to identify you directly such as full name, age, address or employer. We are not responsible for the privacy of identifiable information that you might post to our online community or other public pages of the Site.
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.
Using the App
The App uses information on the content you have viewed. A list of articles or posts that you have recently viewed is chached in the local storage in your mobile device. You can delete this reading history in the App settings. Information on what you have viewed in the App and information on bugs and crashes will also be sent to us. You can choose to receive notifications via the App. You can manage these notification in App settings.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract this means processing your data where it is necessary for the performance of a contract or service to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us by contacting email@example.com.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below the ways we plan to use your personal data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Conducting Our Business
We use the information we collect or receive:
- To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
- To deliver services to the user. We may use your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- To facilitate account creation and login process.
- To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services or Apps.
- To send you marketing and promotional communications.
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To publish testimonials. We may publish testimonials on our Services or Apps that contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at firstname.lastname@example.org and be sure to include your name, testimonial location, and contact information.
- To request feedback. We may use your information to request feedback and to contact you about your use of our Services or Apps.
- To enforce our terms, conditions and policies for business purposes, legal reasons and to fulfil Contractual obligations.
- To respond to legal requests and prevent harm. If we receive a legal request, we may need to inspect the data we hold to determine how to respond.
- For other business purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the 90 Minute Cynic Ltd. group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting email@example.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product or service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
App Access permissions
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out above.
- Internal Third Parties. We may share you data with members of The Cynic staff team in order to provide our services.
- External Third Parties Service such as:
- External contractors, acting as processors or joint controllers based, who provide IT, administrative or system administration services.
- Third-Party Vendors such as: payment processors, data analysis providers, email delivery services, hosting services, customer service and marketing service providers.
- Professional advisers, acting as processors or joint controllers based, including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance or accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Offering our service may involve transferring your data outside the European Economic Area (EEA).]
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards applicable to European legislation.
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact firstname.lastname@example.org.
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Changes to this notice and your duty to inform us of changes
From time to time, this policy may change, where these changes are relevant we will inform users of the amendments and updates to our policies.
This version was last updated on 5th August 2020 and historic versions can be obtained by contacting us.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us at email@example.com.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.