WriteSea Privacy Policy

WriteSea Group Inc. cares about your privacy

 

WriteSea Group Inc. and its subsidiaries and affiliates (hereinafter referred to as “WriteSea”, “we”, “us”, and “our”) respect your privacy and are committed to protecting your personal data. Our Privacy Notice (hereinafter referred to as “Notice”) is designed to communicate our practices regarding the collection, use, retention and disclosure of information and to inform you of your privacy rights and how the law protects you when you access or use the WriteSea site as well as any other website, mobile site or mobile application related or linked to WriteSea (collectively, the “Platform”).

Data Protection Legislation

The General Data Protection Regulation (E.U.) 2016/679 (“GDPR”) is a regulation in E.U. law on data protection and privacy for all individuals within the European Union (E.U.) and the European Economic Area (EEA). It also addresses the transfer of personal data outside the E.U. and EEA areas.

The Data Protection Act¬†2018 (DPA 2018) came into effect on 25 May 2018 and sets out the framework for data protection law in the U.K. It sits alongside the GDPR and tailors how the GDPR applies in the U.K. ‚Äď for example, by providing exemptions. It also sets out separate data protection rules for law enforcement authorities, extends data protection to some other areas such as national security and defence, and sets out the Information Commissioner’s functions and powers.

Federal Act On Data Protection (FADP) The FADP came into force in 1992 – at a time when the Internet was not yet being used commercially and today’s digital reality was not yet foreseeable. On 1 September 2023, the revised FADP came into effect. It includes changes aiming to better protect Swiss citizens’ personal data.

The California Consumer Privacy Act (“CCPA”) is a privacy-centric bill protecting the privacy of California consumers that came into effect on 1 January 2020. Under the CCPA, California residents may have certain data protection rights regarding their personal information (also referred to in this privacy policy as personal data). These rights may be subject to certain limitations and restrictions. Please note that the content below in Section 13 is additional information that applies to California residents only.

The California Privacy Rights Act (CPRA) entered into law on 1 January 2023 and amended the CCPA; it includes limitations and regulations originally enforced by the CCPA. In addition, it added specific types of new amendments to each category covered by the CCPA, enabling a more comprehensive overview of data privacy. The California Privacy Protection Agency will regulate the CPRA.

Data Privacy Frameworks

WriteSea Group Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the U.K. Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. WriteSea Group Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the U.K. Extension to the EU-U.S. DPF. WriteSea Group Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program and view our certification, please visit https://www.dataprivacyframework.gov/.

1. Purpose Of This Policy

This privacy policy aims to inform you how we collect and process your personal data.

It is important that you read this privacy policy to understand how and why we are using your data fully.

Data Controller

WriteSea Group Inc. acts as the data controller and is responsible for your personal data.

2. Contact Details

Our full details are

WriteSea 
Full name of legal entity (Controller)WriteSea Group Inc.
Registered Office Address

100 S Cincinnati Ave 

Suite 533

Tulsa OK 74103 

Name of appointed Data Protection OfficerBrandon Mitchell
DPO Email Addressbrandon@writesea.com 
Name Of E.U. Representative Formiti Data International U.K.
Address of E.U. Representative

Formiti Data International U.K. Ltd,

6 Fern Road,

Dublin,

D18 FP98,

Ireland

EU Representative Contact eurepservice@formiti.com
Name of U.K. RepresentativeFormiti Data International U.K.
Address of U.K. Representative 

Formiti Data International U.K. Ltd,

Grosvenor House, 11 St Paul’s Square,

Birmingham B3 1RB,

United Kingdom

U.K. Representative Contactukrepservice@formiti.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the U.K. supervisory authority for data protection issues: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: 0303 123 1113 (local rate) Live Chat Link.

If you’re a customer within the E.U., you can file a complaint to your local member state data protection authority listed here.

If you are a customer within Switzerland, you can file a complaint to the Federal Council (FDPIC)  by clicking here. 

We would, however, appreciate the chance to deal with your concerns before you approach the ICO local DPA or Swiss Federal Council, so please get in touch with us in the first instance.

3. Changes to the Privacy Notice and Your Duty To Inform Us Of Changes

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

4. Third-Party Links

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 policy of every website you visit.

5. The Data We Collect About You

We collect, use, store and transfer different categories of Personal Data about you, which we have grouped together as follows:

Identity Data: includes but is not limited to first name, last name, username or Social Media Login data, or similar identifier, title, and date of birth.

Contact Data: includes postal address, email address and telephone numbers.

Employment Data: Resume, CV and other Job-Related Data 

Financial Data: includes bank account, payment card details

Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data: Commonly known as online identifiers and includes internet protocol (I.P.) address, unique mobile device identification numbers (such as your Media Access Control (MAC) address, International Mobile Equipment Identity (IMEI), type of device, your login data, browser type and version, time zone setting and geolocation, browser plug-in types and versions, operating system and Platform and other technology on the devices you use to access this website.

Profile Data: information including your username and password, records of your correspondence and engagement with us and feedback and survey responses.

Usage Data: includes information about how you use our website, mobile platforms, products, and services.

Marketing and Communications Data: include your preferences in receiving marketing from us and our third parties and your communication preferences.

Other Sources: We and our affiliates generally share personal data with each other so that we can provide our services to you.  We also may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as LinkedIn, Facebook, etc.), and other third parties.

Data Of Minors: Our Platform is not directed to minors and does not intend to collect personal data from children under 18. Therefore, we recommend that parents or legal guardians be involved in their children’s online activities to prevent collecting their personal data without parental consent. If you believe that we inadvertently collected your child’s personal data, please get in touch with us at support@writesea.com. And we will promptly delete or anonymize this information.

If you decide to make a payment for any of our products and services, your Financial Data, which includes your bank account and payment card details, will be collected and processed by our external payment service provider. We will not have access to, collect, use, store or transfer your Financial Data.

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 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 policy.

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.

If You Fail To Provide Personal Data: 

Where we need to collect 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 access to one of our services or products). 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.

6. Legal Basis For Processing

Our legal basis for processing your personal information varies depending on the type of information we collect and the context in which we collect it.

If you are a resident of the United Kingdom, the European Union, or a jurisdiction where similar legal requirements may apply, such as Brazil, Switzerland, Canada, or the United States, we rely on several legal bases to process information about you. We will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and where we have a legal obligation to process your information. For example, we typically rely on the following:

Consent: when placing cookies on your device on the web (through our cookie consent manager) to send you email marketing or to deliver third-party targeted advertising to you on our services;

Our legitimate interests: to process your information when providing you with customer service support, to serve targeted marketing of our services for fraud prevention and security purposes, and

On contractual necessity: to process information when you create a WriteSea account to enable us to provide you with our services.

Appropriate Notice:  has been provided to or made available to the data subject.

7. How We Collect Your Data 

We use different methods to collect data from and about you, including, but not limited to:

Direct interactions: You may give us your identity data, contact data, and financial data by filling out forms or corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you: 

  • Purchase our products or services.¬†
  • Create an account on our website or via our mobile app.¬†
  • Link your social account to your WriteSea account for account creation.
  • Subscribe to our service or publications.¬†
  • Request marketing to be sent to you.¬†
  • Request support for our products.¬†
  • enter a competition, promotion, or survey; or¬†
  • Provide feedback regarding our services.

8. 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:

  • For the performance of a contract, we are about to enter into or have entered into with you.¬†
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests.¬†
  • Where we need to comply with a legal or regulatory obligation.¬†
  • Where we have your explicit consent.

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. You have the right to withdraw consent to marketing at any time by contacting us or for USA customers exercising your opt-out. The withdrawal of consent will not affect the lawfulness of any processing that took place before the withdrawal.

Purposes For Which We Will Use Your Data 

In a table format, we have described below all the ways we may use your personal data and which of the legal bases we rely on to do so. We have also identified where our legitimate interests are appropriate.

Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.

Purpose / ActivityType of Data Lawful basis for processing, including basis of legitimate interest
To facilitate account creation and logon process.
  • Identity Data
  • Contact Data
  • Financial Data
  • Technical Data
  • Profile Data¬†
Performance of a contract with You
To send administrative information to you, including managing your orders and purchases
  • Identity Data
  • Contact Data
  • Financial Data
  • Technical Data
  • Profile Data
Performance of a contract with You
To send you marketing and promotional communications
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
Consent for E.U., UK, Swiss
To deliver targeted advertising to you.
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
Consent for E.U., UK, Swiss
For other business purposes.
  • Identity Data
  • Contact Data
  • Financial Data
  • Technical Data
  • Profile Data
Business Purposes for USA
To request feedback
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
Legitimate Interest 
To post testimonials.
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
Legitimate Interest
To develop our products and services.
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
Legitimate Interest
To protect the Platform, us, and others.
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
Legitimate Interest
To enforce our terms, conditions and policies.
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
Performance of a contract with You
To respond to legal requests and comply with applicable law.
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
Legal Obligation

Marketing

We provide you with choices regarding our use of your personal data for marketing and advertising purposes. We have established the following personal data control mechanisms:

You will receive marketing communications from us if you have subscribed for an account with us or purchased goods or services from us and you have not opted out of receiving that marketing. All of our marketing communications to you contain an opt-out option, and you can opt-out at any time. Please note that the opt-out will not affect the lawfulness of processing that has taken place before the opt-out.

Third-Party Marketing

For EU/UK/Swiss Customers, We will get your explicit opt-in consent before we share your personal data with any company outside WriteSea Group Inc. for marketing purposes.

Opting Out

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, following the opt-out links on any marketing message sent to you, or contacting us at any time.

iOS – Opt out of interest-based ads in the App Store and Apple News

Android – Opt out of seeing personalized ads

Opting Out Of Third Party Tailored Marketing

If you do not want to receive tailored in-application advertisements from third parties that relate to your interests in our products and services on your mobile device, you may opt out by:

  • Adjusting the ad tracking settings on your device
  • Resetting your Identifier For Advertising (IDFA) from your mobile device’s settings page will prevent continued use of existing behavioural data tied to the previous Identifier For Advertising (IDFA).

Opting Out Of Geolocation

If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device’s settings.

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

A. Do We Use Cookies and Other Tracking Technologies?

Cookies are small text files that are left on your browser when you visit our Site (‚ÄúCookies‚ÄĚ). Your browser saves Cookies on your device‚Äôs hard drive. Some of these Cookies are necessary for the Site to function, others help us improve the Site and make it more user friendly. The information saved with the aid of Cookies can be sent back to our servers when you visit our Site again. There are:

  • First-Party Cookies: these are Cookies which we place on our Site and which are only used by us.
  • Third-Party Cookies: Cookies that are placed on our Site by third parties. Examples of third parties are advertising partners or security providers.

Certain Cookies may collect information that is or can be associated with personal data. Personal data is any information relating to an identified or identifiable natural person. You can find more information about the purposes for which we process your personal data in this Privacy Notice. 

If you have any questions or concerns about our collection or use of your information or the use of Cookies, please contact us at support@writesea.com  

We and our third-party service providers (such as advertising and analytics providers) use cookies and similar tracking technologies (like web beacons, clear GIFs, internet tags, and pixels) to gather information when you interact with our websites and email communications. Some tracking technologies help us maintain the security of our websites and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. We also permit third parties to use tracking technologies on our websites for analytics to understand how visitors interact with our websites. For example, we use Google Analytics to evaluate website traffic and usage data to help us improve our products and services. For more information about how Google collects and processes data visit https://policies.google.com/technologies/partner-sites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/, and for Adobe please visit https://www.adobe.com/privacy/opt-out.html. In addition, we may permit third parties to use tracking technologies on our websites for advertising, including to help manage and display advertisements, and to tailor advertisements to your interests. The third parties use their technology to provide advertising about products and services tailored to your interests which may appear either on our websites or on other websites. This is sometimes referred to as third-party behavioural advertising.

Please review our Cookie Policy for additional information below:

B. Which Cookies Do We Use? 

We select our Cookies prudently. We work with certain third parties to collect data through Cookies, but we are neither responsible nor liable for the processing of personal data by these third parties, and can therefore not guarantee that these third parties will handle your personal data in a reliable and secure manner. You should always read the privacy and Cookie policies of other websites or tools before using them. If you want to know more about Cookies in general, please refer to the website all about Cookies (https://allaboutcookies.org/).

In addition to Cookies, we also use tracking and other technologies that can be very similar. Our Site may contain small transparent image files or codes that record information about you. These are, for example, ‚Äėscripts‚Äô, ‚Äėweb beacons‚Äô or ‚Äėtracking URLs‚Äô. These technologies are also referred to as Cookies.

Below we explain, among other things, which types of Cookies we use and for what purposes.

1. ESSENTIAL COOKIES

These Cookies are essential for our Site’s core activity and are automatically activated when you use the Site. These Cookies are for example used to remember your account details, your selected language settings and your previous searches, so that you can use our Site efficiently and effectively. These Cookies also include the enabling of essential security and accessibility features so that you can safely use our Site. We also save your permission settings in a Cookie to remember these for future visits.

We may use these essential Cookies without your consent. Because these Cookies are necessary for the Site to work, you cannot opt out of this category. However, the Cookies will never be used for any purpose other than ensuring the functionality of our Site.

2. ANALYTICAL COOKIES

These Cookies help improve the performance of the Site and provide a better user experience. This enables us to offer you a high quality experience by adapting our Site and content and identifying and resolving problems quickly. For example, we use performance Cookies to monitor which pages are most popular, which method of navigation between pages is the most effective, and to ascertain why some pages receive error notifications.

We also use Google Analytics. When enabled, Google will collect visitation information and associate it with Google information from accounts of signed-in users who have consented to this association for the purpose of analytics and personalization. This Google information may include the end user location, search history, YouTube history, and data from sites that partner with Google, and is used to provide us aggregated and anonymized insights into our users’ cross device behaviors. We therefore see global statistics and anonymized data.

You can read more about Google Analytics here (English), and also opt out of Google Analytics at any time here (English). Your data with Google may be accessed or deleted via My Activity. You can also refuse these Cookies by changing your browser settings. Please refer to the section ‚ÄúHOW CAN I CONTROL COOKIES?‚ÄĚ. Should anything change with regard to the rules on the use of Google Analytics, we will adjust our use accordingly.

3. MARKETING AND TRACKING COOKIES

We collaborate with third parties to display advertisements on our Site or to manage advertisements on other sites. Those third parties can use technologies such as Cookies to collect information about your activities on this Site and other sites in order to offer you advertising based on your browsing activities and interests. You can refuse these First-Party and Third-Party Cookies by changing your browser settings. Please refer to the section ‚ÄúHOW CAN I CONTROL COOKIES?‚ÄĚ.

For example, Google may not share your information with other advertisers. If required, they may share this information to comply with applicable laws, regulations, legal process or governmental requests.

B. Social Media Buttons

Our Site may contain buttons, widgets, tools or content that link to services from other companies (for example, Facebook ‚Äėlike‚Äô or ‚Äėshare‚Äô buttons). We may collect information about your use of these functions. In addition, when you see or use these buttons, tools or content, or if you view a web page that contains these, certain information from your browser can be sent to the other company automatically.¬†

C. How Do I Find Out The Exact Cookies And Retention Periods?

Cookie check via any internet browser

  • Press F12 or right-click on the page and select ‚Äúinspect.‚Ä̬†
  • Click on ‚ÄúApplication.‚ÄĚ
  • On the left side of the ‚Äúinspect‚ÄĚ frame, click on the ‚ÄúCookies‚ÄĚ option under ‚ÄúStorage.‚Ä̬† You may need to click on the URL address under ‚ÄúCookies‚ÄĚ to display how many cookies are set, the names and retention periods.¬†

D. How Can I Control Cookies?

If you want to accept or decline certain categories of Cookies, you can do that via our Cookie banner on our Site. This tool is automatically loaded when you visit the Site for the first time. We give you the option of accepting or declining certain Cookies, with the exception of the essential Cookies. 

In addition, you can also change your web browser settings to decline Cookies. In that case, our Site may no longer function properly. More information on how to enable, disable and delete Cookies can be found in the instructions for your internet browser. We always recommend that you check whether your internet browser is up to date. For this purpose, you can use the help and support button of your internet browser. 

If we process personal data through our Cookies, we can also delete or anonymize your personal data on request, unless we are subject to a statutory retention obligation. For more information on your rights in respect of your personal data and how to exercise these rights, on the security measures we have taken and on any potential data transfers, please refer to our Privacy Notice.

You can submit requests for the exercise of your rights to us at support@writesea.com

E. How Do We Handle Your Social Logins? 

The Platform, one of our websites or mobile applications may offer you the ability to register and login using your third party social media account details (like your Facebook or X logins). If you choose to do this, we will receive certain profile information about you from the social media company. The profile information we receive may vary depending on the social media provider, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive for the purposes that are described herein. 

Please note that we do not control, and are not responsible for, other uses of your personal data by the social media company. We recommend that you review their privacy policy to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and applications.

G. How Long Do We Keep Your Information? 

We will only keep your personal data for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).  

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it.

Cookies and Tracking Technologies

Some tracking technologies help us maintain the security of our websites and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. These tracking technologies are ‚Äúnecessary‚ÄĚ because we need them for the websites to work properly. We don‚Äôt provide the option to opt-out of these tracking technologies, but you can remove these ‚Äúnecessary‚ÄĚ tracking technologies by modifying your browser settings. Please note, some features of our websites may not be available to you as a result.

You may choose whether to allow or disallow other types of tracking technologies used to enable a website to remember certain information that changes how the website looks (preference cookies), to help us understand how visitors interact with our website (statistics cookies), and to track visitors across websites and which may be used to display ads that are more relevant or engaging for the individual visitor (marketing cookies). 

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 we need to use your personal data for an unrelated purpose, we will notify you and obtain your consent 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.

This Policy and other documents referenced in it apply to all personal data collected through our Platform and any related services, sales, marketing or events. 

9. Disclosure Of Your Personal Data 

We may share your personal data with third parties set out below for the purposes set out in the table in section 8 above.

  • Specific marketing partners are listed here.
  • Third-party service providers:
    • Advertising, direct marketing, and lead generation¬†providers
    • Chat service providers
    • Content optimization¬†service providers
    • Invoice and billing¬†service providers
    • Social media companies to which you enable access
    • Social media site advertising
    • Software service providers that parse and match resumes with job postings
    • Targeted advertising platforms
    • Website and application analytics providers
    • Website hosting providers
    • Website testing and optimization service providers

We may seek to acquire or merge with other businesses, or part of our business may be sold. If a change happens to our business, then your personal data may be disclosed to our advisers, and those of any prospective purchaser or partner, and the new owners or partners may use your personal data in the same way as set out in this privacy policy. Your data will only be disclosed for the purposes identified in this privacy policy (as may be updated from time to time) unless a law or regulation specifically allows or requires otherwise. 

We require all third parties to respect the security of your personal data and treat it according to 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. All our third-party processing partners are vetted under our third-party due diligence process and have signed data processor contracts with us.

10. International Transfers

Some of our external third parties are based outside the European Economic Area (EEA), the United Kingdom and Switzerland, so their processing of your personal data will involve a transfer of data outside the U.K., the EEA and Switzerland.

External Partner Category

Transfer Purpose

Lawful Basis

a) Technical partner

a) Provide technical processing services

a) Performance of a contract with You

b) Marketing partner

b) Provide marketing services

b) Consent for EU/UK/Swiss Customers

c) Advertising partner

c) Provide Advertising Services

b) Consent for EU/UK/Swiss Customers

When transferring your personal data out of EU/UK/CH, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • The third-party receiving party is registered under the EU-U.S. Data Privacy Framework- U.K. Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF)
  • Appropriate safeguards are in place in accordance with data protection laws. These safeguards include the use of standard contractual clauses/ data protection clauses approved by the U.K. Secretary of State or the European Commission (as appropriate) or binding corporate rules for third countries not having adequacy decisions.
  • The transfer is otherwise allowed under data protection laws (including where we have your consent, or the transfer is necessary for the performance of a contract with you.
  • WriteSea maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our EU-U.S. DPF Principles obligations, including the onward transfer provisions, and WriteSea remains liable if we fail to meet those obligations and we are responsible for the event giving rise to damage.

11. Data Security 

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, disclosed or unavailable. In addition, we limit access to your personal data to those employees, agents, professional advisers, contractors, and other third parties who have a business need to know on the principle of least privilege (PoLP). They will only process your personal data on our instructions and are subject to a duty of confidentiality. We periodically review all privacy and security policies and update them when necessary, in line with changes in data protection laws or when new technologies are introduced into our business.

Where the introduction of new technologies results in a high risk to your personal data, we will perform a data protection impact assessment and will only proceed if we are able to mitigate any identified high risks. Methods of collecting personal data are reviewed by management before they are implemented to confirm that personal data is obtained:

  • Fairly, without intimidation or deception, and
  • Lawfully adhering to all relevant rules of law, whether derived from statute or common law, relating to the collection of personal data.

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.

12. Data Retention

How Long Will You Use My Personal Data 

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. A copy of our Data Retention Schedule is available upon request.

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 unauthorized 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.

In some circumstances, we may anonymize 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.

DATA DISPOSAL

Once the data retention periods above expire, digital records are permanently destroyed or fully anonymized if retained for statistical or research purposes. In this case, all personal identifiers are removed permanently so individuals cannot be identified.

13. Your Legal Rights

Under certain global applicable laws (including U.K. and E.U. data protection laws) and under certain circumstances, you have rights in relation to your personal data. We set out below a brief description of such rights:

To be informed: Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under U.K. and E.U. data protection laws. This privacy policy and our cookie policy meet this requirement.

Request access to your personal data (commonly known as a “data subject access request” ): This enables you to receive a copy of the personal data we hold about you subject to certain exemptions.

  • Request rectification of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide.
  • Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we have a legal obligation to erase your personal data. Note, however, that the right to request erasure is not absolute, and there are circumstances where we do not need to comply with the request, which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data: This enables you to object to processing where we are relying on our legitimate interest (or those of a third party) to process your personal data or where we are processing your personal data for scientific or historical research or statistical purposes. We do not need to stop processing if we can give strong and legitimate reasons to continue processing your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. This is an absolute right but does not automatically mean we need to erase all your personal data. In particular, we may put your details on a suppression list to ensure we don’t send you direct marketing in the future.
  • Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data in certain scenarios, including (a) if you want us to establish the data’s accuracy; or (b) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or a third party: We will provide your personal data to you or a third party you have chosen in a structured, commonly used, machine-readable format. Note that this right only applies to personal data you provided to us, which you initially provided consent for us to use or where we used the personal data to perform, or take steps before performing, a contract with you and where the processing is automated.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may be unable to provide you with certain products or services. We will advise you if this is the case when you withdraw your consent.

Please note that the above rights are not all absolute and are subject to applicable data protection law and may be subject to conditions and provisions set out in applicable data protection laws. For further information or if you wish to exercise any of the rights set out above, please contact us.

No Fee Is Usually Required

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 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 which case we will inform you of an extension period of up to 2 months. In this case, we will keep you informed on progress.

14. Glossary

Lawful Basis

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance Of A Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation: means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to

Explicit consent: for external marketing, your personal data will not be disclosed to any third party unless you have given explicit consent.

15. Federal Trade Commission (FTC) Oversight:

We are subject to the investigatory and enforcement powers of the Federal Trade Commission.

16. Independent Recourse Mechanism:

the rules and mechanism of the International Centre for Dispute Resolution-American Arbitration Association (ICDR-AAA) available at https://go.adr.org/dpf_irm.html and shall be used to resolve any disputes that cannot be resolved directly by the parties as necessary. We are obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles available at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf, provided that an individual has invoked binding arbitration by delivering notice to WriteSea and following the procedures and subject to conditions set forth in Annex I of Principles.

17. Policy Updates

Policies and procedures are reviewed and compared to the requirements of applicable laws and regulations at least annually, and whenever changes to such laws and regulations are made, privacy policies and procedures are revised to conform with the requirements of applicable laws and regulations.

Version and Review

This Policy is Version is V.003 dated 12/27/2023

This Policy will be next reviewed on 11/26/2024 unless it requires urgent updates due to a law change.

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