PRIVACY POLICY
This Privacy Policy sets out how I, The Thyroid Diaries, collect, store and use information about you when you use or interact with my website, thethyroiddiaries.com (my website) and where I otherwise obtain or collect information about you. This Privacy Policy is effective from 18 July 2022.
If you have any questions about my Privacy Policy, please contact me by sending an email to EMAIL_TO_BE_DEFINED
Contents
. My details
. Information I collect when you visit my website
. Information I collect when you contact me
. Disclosure and additional uses of your information
. How long I retain your information
. How I secure your information
. Transfers of your information outside the European Economic Area
. Your rights in relation to your information
. Your right to object to the processing of your information
. Sensitive Personal Information
. Changes to my Privacy Policy
. Additional Information
My Details
- Data controller
You can contact the data controller by sending an email to EMAIL_TO_BE_DEFINED.
If you have any questions about this Privacy Policy, please contact the data controller.
Information I collect when you visit my website
I collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
- Web server log information
I use a third party server to host my website. My website server automatically logs the IP address you use to access my website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to my website (e.g. the website or URL (link) which referred you to my website), and your browser version and operating system.
My server is located in Portugal.
Use of website server log information for IT security purposes
My third party hosting provider stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to my network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless I am investigating suspicious or potential criminal activity, I do not make, nor do I allow my website server provider to make any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which I am subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: I have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of my processing of information about individuals. Recording access to my website using server log files is such a measure.
Legal basis for processing: my legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: I have a legitimate interest in using your information for the purposes of ensuring network and information security.
- Cookies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
I use cookies, including essential, functional and analytical cookies.
You can reject some or all of the cookies I use on or via my website by changing your browser settings, but doing so can impair your ability to use my website or some or all of its features.
Information I collect when you contact me
I collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on my website, I collect your email address and any other information you provide in that email (such as your name, email and the information contained in any signature block in your email).
Legal basis for processing: my legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages I receive and keeping records of correspondence.
Transfer and storage of your information
I use a third party email provider to store emails you send me. My third party email provider is based in the Portugal.
Emails you send me will be stored inside the European Economic Area.
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which I use your information.
- Disclosure of your information to service providers
I use a number of third parties to provide me with services which are necessary to run my blog or to assist me with running my blog and who process your information for me on my behalf. These include the following:
- Telephone providers (CN),
- Email provider (PT),
- IT service providers (PT),
- Web developers (PT), and
- Hosting provider (PT).
All my service providers are located in Portugal except the mobile phone which comes from a provider in United States.
Your information will be shared with these service providers only where necessary to enable me to run my blog.
- Disclosure of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If I suspect that criminal or potential criminal conduct has been occurred, I will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if I suspect that a fraud or a cyber crime has been committed or if I receive threats or malicious communications towards me or third parties.
I will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: my legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement my legal rights
I will use your information in connection with the enforcement or potential enforcement of my legal rights, including sharing information with debt collection agencies if you do not pay amounts owed to me when you are contractually obliged to do so. My legal rights may be contractual (where I have entered into a contract with you) or non-contractual (such as legal rights that I have under copyright law or tort law).
Legal basis for processing: my legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing my legal rights and taking steps to enforce my legal rights.
In connection with a legal or potential legal dispute or proceedings
I may need to use your information if I am involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: my legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
I will use and process your information in order to comply with legal obligations to which I am subject.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of Portugal or if they have been integrated into Portugal’s legal framework (for example in the form of an international agreement which Portugal has signed).
Legal basis for processing: my legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into Portugal’s legal framework, I have a legitimate interest in complying with these obligations.
- Disclosure of your information to other third parties
I disclose your information to other third parties in specific circumstances, as set out below.
Providing information to Google Inc.
Google collects information through my use of Google Analytics on my website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the partners page of Google’s privacy policy
Legal basis for processing: my legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting my contractual obligations to Google under my Google Analytics Terms of Service and allowing the Google Analytics to work on my website
You can opt out of Google Analytics by installing the browser plugin here
Sharing your information with third parties, which are either related to or associated with the running of my blog, where it is necessary for me to do so. These third parties include my accountants, advisors, affiliates, blog partners, independent contractors, and insurers
Further information on each of these third parties is set out below.
Legal basis for processing: my legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing my blog efficiently.
Blog partners
Blog partners are entities I work with which provide goods and services which are complementary to my own or which allow me to provide goods or services which I could not provide on my own. I share information with my blog partners where you have requested services which they provide whether independently from, or in connection with or own services.
My blog partners are located in Europe.
How long I retain your information
This section sets out how long I retain your information. I have set out specific retention periods where possible. Where that has not been possible, I have set out the criteria I use to determine the retention period.
- Specific retention periods
Correspondence and enquiries: when you make an enquiry or contact me by email or via my contact form, I will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further month(s), after which point I will delete your information.
- Criteria for determining retention periods
In any other circumstances, I will retain your information for no longer than necessary, taking into account the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform my obligations under a contract with you or to contact you in the future);
- whether I have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- whether I have any legal basis to continue to process your information (such as your consent);
- how valuable your information is (both now and in the future);
- any relevant agreed industry practices on how long information should be retained;
- the levels of risk, cost and liability involved with me continuing to hold the information;
- how hard it is to ensure that the information can be kept up to date and accurate; and
- any relevant surrounding circumstances (such as the nature and status of my relationship with you).
How I secure your information
- Measures taken to secure your information
I take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- using secure servers to store your information;and
- verifying the identity of any individual who requests access to information prior to granting them access to information.
- Transmission of information to use by email
Transmission of information over the internet is not entirely secure, and if you submit any information to me over the internet (whether by email, via my website or any other means), you do so entirely at your own risk.
I cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to me by such means.
Transfers of your information outside European Economic Area
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below.
I will also transfer your information outside the EEA or to an international organisation in the unlikely event that I am required to comply with legal obligations to which I am subject (compliance with a court order, for example). Where I am required to do so, I will ensure appropriate safeguards and protections are in place.
Information you submit to me by email is transferred outside the EEA and stored on my third party email provider’s servers.
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: my third party email provider has self-certified its compliance with the EU-U.S. Privacy Shield which is available here. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here.
Your rights in relation to your information
- Your rights
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to EMAIL_TO_BE_DEFINED:
- to request access to your information and information related to my use and processing of your information;
- to request the correction or deletion of your information;
- to request that I restrict my use of your information;
- to receive information which you have provided to me in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- to withdraw your consent to my use of your information at any time where I rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of my use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
- Verifying your identity where you request access to your information
Where you request access to your information, I am required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How I verify your identity
Where I possess appropriate information about you on file, I will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if I have insufficient information about you, I may require original or certified copies of certain documentation in order to be able to verify your identity before I am able to provide you with access to your information.
I will be able to confirm the precise information I require to verify your identity in your specific circumstances if and when you make such a request.
Sensitive Personal Information
- What is “Sensitive Personal Information“
“Sensitive personal information” is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
- Out policy on Sensitive Personal Information
I do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to me processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. I will use and process your sensitive personal information for the purposes of deleting it.
Changes to my Privacy Policy
- Minor changes to my Privacy Policy
Where I make minor changes to my Privacy Policy, I will update my Privacy Policy with a new effective date stated at the beginning of it. My processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
- Major changes to my Privacy Policy
Where I make major changes to my Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which I originally collected it, I will notify you by email (where possible) or by posting a notice on my website.
I will provide you with the information about the change in question and the purpose and any other relevant information before I use your information for that new purpose.
Wherever required, I will obtain your prior consent before using your information for a purpose that is different from the purposes for which I originally collected it.
Additional Information
- Children’s privacy
Because I care about the safety and privacy of children online, I comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. I do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that I could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If I am notified of this, as soon as I verify the information, I will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if I am unable to obtain such parental consent, I will delete the information from my servers. If you would like to notify me of my receipt of information about persons under the age of 18, please do so by sending an email to EMAIL_TO_BE_DEFINED
- Copyright
The copyright in this Privacy Policy is either owned by, or licensed to, me and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.