Last Updated: 28 APRIL 2023
1.0 INTRODUCTION
This privacy policy (“Policy”) describes how Smart Cookie Solutions Inc. (“Company,” “we,” “us,” and “our”) collects, processes, uses, protects and shares personal data when using its website with domain name thegoutsite.com (“Site”). The Policy also explains certain legal rights that you have with respect to your personal data.
Your privacy and that of all our visitors to this site are very important to us. We respect your privacy and are committed to protecting it through this Policy. Please read the following information carefully to understand our practices regarding your personal data and how we will process data.
1.1 Purposes of Processing
We collect information about you in a range of forms, including personal data.
As used in this Policy, “personal data” is as defined in the General Data Protection Regulation (EU) 2016/679 (“GDPR”), this includes any information which, either alone or in combination with other information we process about you, identifies you as an individual including, for example, your name, postal address, email address and telephone number. Your Internet protocol address (“IP address”) is also included in the GDPR’s definition of personal data.
1.2 Why do we need your personal data?
We will only collect and process your personal data in accordance with applicable data protection and privacy laws.
We will collect and process your personal data where there is a contractual or statutory requirement for us to do so, for example, when you purchase any of our products or services or when you purchase any third-party products or services that we recommend or advertise on our Site and for which we will receive a sales commission.
We will collect and process your personal data when you opt-in to an email list through an opt-in form on our Site in order to receive free informational material delivered by email, for example, a free monthly newsletter or free report. You can opt-out of receiving these emails at any time by clicking the unsubscribe link at the bottom of every email we send to you.
We will automatically collect and process your personal data when you first enter our Site. We do this to help improve Site performance and functionality, to personalize certain features, and to analyze visitor behavior. We do this using “cookies” (see section 3).
1.3 What happens if you do not give us your personal data?
If you do not provide us with sufficient personal data, we may be unable to provide you with products and services you may wish to purchase from us and any free material you may wish to receive from us.
In addition, if you do not provide us with sufficient personal data, you may be unable to access interactive on-Site services, for example, post commenting.
However, you will be able to enter and use most of our Site without giving us your personal data, for example, general browsing activities.
2.0 COLLECTING YOUR PERSONAL DATA
We collect information about you in the following ways:
2.1 Information You Give Us Voluntarily
This includes:
- the personal data you provide when you register to receive free offers that we may post on our Site from time to time, which will normally be your first name and email address;
- the personal data that may be contained in any comment you post to the Site;
- the personal data you provide in connection with any promotions we may run on the Site from time to time;
- the personal data you provide when you report a problem with our Site or when we provide you with customer support;
- the personal data you provide when you make a purchase thorough our Site; and
- the personal data you provide when you correspond with us by phone, email or otherwise.
2.2 Information Automatically Collected By Us
To help us continually improve Site visitor experience and functionality we analyze each Site visitor’s behavior using information we automatically receive from their browser or mobile device via “cookies” (see Section 3).
For example, when you enter our Site, we automatically collect and log:
- your Internet service provider’s name;
- your computer’s / mobile’s / proxy server’s IP address;
- your computer or mobile device operating system name;
- your device’s screen resolution;
- your web browser type and language;
- the name of the website you visited before entering our Site;
- pages you viewed on our Site;
- how long you spent on each page;
- access times and other information about your use of and actions on our Site; and
- the name of the website you visited after browsing our Site.
We use third-party Google Analytics for this purpose (see Section 3: Analytics and Performance Cookies).
2.3 Automated Individual Decision-Making and Profiling.
We do NOT use your personal data for the purposes of “automated individual decision-making” (making a decision solely by automated means without any human involvement) and “profiling” (automated processing of personal data to evaluate certain things about an individual). However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
3.0 COOKIE NOTICE
Like many websites and online services, our Site automatically collects information using cookies. We use cookies for the proper functioning of the Site and third-party services such as payment processing, email management, Site analytics, and on-Site advertising.
3.1 What are Cookies?
Cookies are small data files which are placed and stored on your computer or mobile device by a website when you first visit it. The next time you visit that site your computer or mobile device checks to see if it contains a relevant cookie and sends the information contained in that cookie back to the site. The site then ’recognizes’ that you are a return visitor and tailors site functionality and your overall on-site experience to take account of the fact.
Without cookies, and depending on the type of website, some site features will cease to function properly, for example, shopping cart features, on-site purchases, on-site forms, and logging-in / authentication. And without cookies most websites will run more slowly and less efficiently resulting in a poor visitor experience.
We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies:
(1) First-party cookies: which are served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site and are used for Site performance and functionality; and
(2) Third-party cookies: which are served by third-party service providers on our Site (with our permission) in order to provide us with services such as payment processing, email management, Site analytics, and advertising.
Third-party service providers used on our Site with our permission are:
- Stripe: to process your payment when you buy products or services from us;
- Google Analytics: for analyzing visitor behavior on our Site;
- Google Ad Network: for placing relevant advertising on our Site (from time to time);
- GetResponse: for providing email facilities between us and you when you buy products or services from us or when you opt-in to receive free material by email from us.
These third parties have their own privacy and cookie policies which you can read here:
Google Analytics Privacy Policy
Google Ad Network Privacy Policy
3.2 Cookies We Use
Our Site uses the following types of cookies for the purposes set out below:
3.2.1 Essential Cookies
These cookies are essential to provide you with specific features on our Site, for example, the ability to buy our products and services and any third-party products and services that we may, from time to time, promote on the Site and for which we will receive a sales commission. Without essential cookies, these services cannot be provided.
We use Stripe, Inc. to process your payments when you buy a product or service from us. We do not process or store your personal information when you make a purchase from us. Instead, when you click on a ‘buy’ button on our Site, you are immediately connected to the Stripe website where Stripe will ask for, process and store, sufficient personal data to complete the transaction. You can read how they do this here: Stripe Privacy Policy.
Should you click on a third-party promotional link on our Site, you will immediately be connected to that third-party website where you may make a purchase. In order for the third-party merchant to pay our sales commission, they need to identify that you bought their product or service on their website via a special link on our Site. They do this using a cookie that contains our unique affiliate identifier that they can link to your purchase. We do not process or store your personal information when you make a purchase from the third-party website. Each third-party website will have its own privacy policy.
3.2.2 Functionality Cookies
These cookies allow websites to remember choices users make, such as, language preferences, post comment submissions, forum submissions, login details, and any changes users have made to the website (where that is allowed). They are also used to deliver certain features such as watching videos and listening to audio podcasts on the website.
The purpose of these cookies is to provide users with a more personalized experience and to avoid users having to re-enter their preferences every time they revisit the website. If a user deletes these cookies, their preferences or settings will not be retained and the user will have to re-enter them every time they visit the website. Additionally, features such as videos and audio podcasts will not function properly.
Functionality cookies are used on our Site.
3.2.3 Analytics and Performance Cookies
These cookies are used to collect information about traffic (visitors) to our Site and how such visitors use our Site. The information gathered does not identify any individual visitor. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics (a web analytics service provided by Google, Inc.) for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
3.2.4 Targeted and Advertising Cookies
From time to time we may place advertisements on our Site. If and when we do, these cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.
You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices.
If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
3.2.5 Social Media Cookies
These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.
3.3 Disabling Cookies
Any personal information that we or third parties on our Site collect and store through use of cookies are based on your consent, obtained through a conspicuous disclosure on our Site during your first visit.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help,” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Note: If you do not accept our cookies, you may experience some inconvenience in your use of our Site.
4.0 ADVERTISING
From time to time we may use other companies to serve third-party advertisements when you visit and use our Site.
These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Site and other websites, in order to provide advertisements about goods and services likely to be of interest to you.
These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
5.0 USING YOUR PERSONAL DATA
We may use your personal data as follows:
- to operate, maintain, and improve our Site, products, and services;
- to manage your account, including to communicate with you regarding your account, if you have an account on our Site;
- to operate and administer our rewards program and other promotions you participate in on our Site;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- with your consent, to send you marketing emails about upcoming promotions, and other news, including information about products and services offered by us and by third parties for which we receive a sales commission. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
- to process payments you make via our Site;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others;
- for analysis and study services; and
- as described in the “Sharing of your Personal Data” section below.
6.0 SHARING YOUR PERSONAL DATA
We may share your personal data as follows:
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
- Our Third-Party Service Providers. We may share your personal data with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
7.0 THIRD PARTY SITES
Our Site may contain links to third-party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
This disclaimer includes third-party websites some of whose content may have been embedded in our Site’s pages, for example, videos and images. These third-party websites may collect data for our pages where their content has been embedded.
8.0 USER GENERATED CONTENT
You may share personal data with us when you submit user generated content to our Site, for example, when you leave a comment on a post. Please note that any information you post or disclose on our Site will become public information, and will be available to other users of our Site and to the general public.
We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Site. Such personal data and other information will not be private or confidential once it is published on our Site.
If you provide feedback to us, we may use and disclose such feedback on our Site, provided we do not associate such feedback with your personal data. However, if you have provided your consent to do so, we may post your first and last name along with your feedback on our Site. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.
9.0 INTERNATIONAL DATA TRANSFER
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By accepting this Policy, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
10.0 SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us by email to: nowsgoodlimited@gmail.com quoting the website name and / or domain name.
11.0 RETENTION
We will retain your personal data only for as long as we require it for business, contractual, legal, or tax reporting purposes. We may retain your personal data in electronic or paper form, or a combination of both. When your information is no longer required, we will destroy, delete, or erase it.
12.0 OUR POLICY ON CHILDREN
We will not knowingly collect or use personally identifiable information from anyone under 16 years of age.
Under our Terms & Conditions children under 16 years of age are not permitted to use this Site. Nor are children under 16 years of age permitted to enter any personal details into any form or other location on this Site. By continuing to use this Site you are confirming that you are 16 years of age or over.
If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as is reasonably practicable.
13.0 YOUR RIGHTS
- Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Site may be ineffective upon opt-out.
- Access. You may access the information we hold about you at any time by contacting us directly.
- Amend. You can also contact us to update or correct any inaccuracies in your personal data.
- Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example, when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
13.1 Exercising Your Rights
If you wish to exercise any of these rights, please contact us by email to the address given in section 15.
In your request, please make clear: (i) our website name and / or domain name; (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce.
For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within 30 days of your request.
Please note that we may need to retain certain information for recordkeeping purposes, for example, for our statutory business and tax accounting records (6 years), and/or to complete any transactions that you began prior to requesting such change or deletion.
14.0 COMPLAINTS
We are committed to resolve any complaints about our collection or use of your personal data.
If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us by email to the address given in section 15.
We will reply to your complaint as soon as we can and in any event, within 30 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.
15.0 Contact Information
We welcome your comments or questions about this Policy. You may contact us by email to info@thegoutsite.com quoting the website name and / or domain name.