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PRIVACY NOTICE FOR BEACON PUBLISHING LTD
1. WHO ARE YOU AND WHAT IS BEACON?
1.1 We are Beacon Publishing Ltd of 6 Trossachs Gardens, Belfast, Northern Ireland, BT10 0HX (we, us, our).
1.2 We provide you with a software-as-a-service tool (Software) to enable you to transform your internet blog posts
into professionally designed, downloadable content (Service). The Service is provided on each of a free and a paid
basis.
2. WHAT IS THIS NOTICE?
2.1. From time to time we may need to process Personal Data (which is information which can be used to identify
someone) in connection with our Service. This Personal Data may be about you or other people. This notice explains
how we will use any Personal Data we hold.
2.2. We hold Personal Data about the following groups of people (Data Subjects):
(i) a Customer: this is an individual who has registered to use the Service (whether on the free or paid basis).
We call this data Customer Data;
(ii) a Customer’s Data Subject: this is any individual whose Personal Data is contained in any content is uploaded
by you as a Customer into the Software. For example, if you use the Service to improve a blog that you have
posted about named living people, each of those people would be a Customer’s Data Subject. We call this
data Customer’s Data Subject Data.
2.3. As part of our Service, we may need to transfer Personal Data about Data Subjects to third parties (for more details
on this have a look at paragraph 8 below). This notice only deals with our use of Personal Data. The people we
transfer Personal Data are not bound by this privacy notice. This notice should make it clear exactly when and to
whom data may be transferred – but if you have any questions feel free to send us an email at kevin@beacon.by
2.4. We might need to change this privacy notice from time to time. We will publish our privacy notice on our website
(available at www.beacon.by) and do our best to update you directly if we think the changes might affect you. Please
do keep an eye on our notice before sending us any Personal Data or uploading it into the Software.
3. ARE YOU A CONTROLLER OR A PROCESSOR?
3.1. It depends on who the data is about and where it came from:
(a) We are a Controller in respect of any Customer Data which we hold. This means that we make decisions
about what types of Personal Data we think we need to collect about our Customers and how to use it to
make our business work.
(b) We are a Processor in respect of any Customer’s Data Subject Data which we hold. This means we use the
Customer’s Data Subject Data provided by you strictly and only in accordance with your instructions and not
for our own purposes. The only decisions we make in respect of this data are procedural. You are the
Controller in relation to the Customer’s Data Subject Data you provide to us.
4. WHAT PERSONAL DATA DO YOU COLLECT AND WHERE DO YOU GET IT FROM?
Customers
4.1 We may collect and store the following data about you as our Customer:
(i) Information a Customer provides us with directly. This might include:
• In relation to the free version of the Service, your company/business’s name, your email address and
password, your forename and surname and your social media user names and passwords;
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PRIVACY NOTICE FOR BEACON PUBLISHING LTD
• In relation to the paid service, all of the above together with your full address, VAT number (if
applicable), your credit card number and your internet protocol address.
• Information about your business, workforce and needs;
• Information about requests, disputes or responses to surveys; and
• Information about your marketing preferences.
• Transaction data about services provided to you.
(ii) Information which we collect automatically. This might include:
• Usage data: which might include information about how you use our website or Service;
• Traffic data: which might include information about websites, ads or links clicked on by you before,
during or after visiting our website or Service;
• Technical data: which might include information about the device used by you to access our website
or Service.
For more information about what cookies we use, please see our Cookies Policy, which can be accessed here:
http://beacon.by/assets/docs/Cookie_Policy.pdf
Customer’s Data Subject Data
4.2 In relation to Customer’s Data Subject Data, we will collect and store any and all Personal Data provided by you in
relation to each of your Customer’s Data Subjects.
5. HOW WILL YOU USE THE PERSONAL DATA YOU HOLD AND WHAT IS YOUR LAWFUL BASIS FOR DOING SO?
Customer Data
(i) We hold and process data about you as our Customer as a Controller, which means we must have a ‘lawful basis’
for doing so. We have set out how we use this Personal Data along with our lawful basis in the table below.
(ii) Anywhere we are relying on legitimate interest we believe that such processing is necessary for the purposes of our
legitimate interest, which in this case is to function as a business. We consider such use goes no further than a
Customer would reasonable expect; is likely to align with the Customer’s interests (by enabling us to provide a
sustainable business model) and is unlikely to be detrimental to the fundamental rights and freedoms of our
Customer.
(iii) We may collect aggregate data about our Customers’ use of Software. Any such data will be anonymised and used
for business and market research purposes.
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PRIVACY NOTICE FOR BEACON PUBLISHING LTD
PURPOSE/ DESCRIPTION TYPES OF LAWFUL BASIS
ACTIVITY DATA
To provide our To provide our Service which may include Identity Data Necessary for the
services support and maintenance of your account Contact Data performance of the contract
and facilitating the set-up and managing Transaction with you for the provision of
payment Data our services or taking steps
necessary to enter into a
contract.
To manage our To notify you of updates to our services or Identity Data Necessary for the
relationship software or updates to our privacy notice Contact Data performance of the contract
with you with you for the provision of
our services or taking steps
necessary to enter into a
contract.
Legitimate Interest
Administration We may also need to process Personal Identity Data Legitimate Interest
and Dispute Data about you to meet our internal Contact Data
Resolution administration requirements and for Transaction
matters such as dispute resolution. Data
Marketing From time to time we might contact you by Identity Data Legitimate Interest
telephone or email about updates to our Contact Data
services, new features or functions or new Transaction
products we are bringing out. We will Data
always include the right to opt out in any Profile Data
such correspondence. Traffic Data
We may also use third party services which
enable us to promote services to you on
third party websites or platforms.
Our marketing may be tailored on the basis
of what we think your interests are (from
looking at traffic and usage data collected
using cookies and other similar
technologies as well as past transactions
and interactions).
Customer’s Data Subject Data
(i) Since we are acting as a Processor in respect of any Customer’s Data Subject Data, we will only use it in accordance
with your instructions.
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PRIVACY NOTICE FOR BEACON PUBLISHING LTD
6. DO YOU DISCLOSE PERSONAL DATA TO ANYONE ELSE?
DATA SUBJECT TYPES OF DATA RECIPIENT REASON FOR TRANSFER RECIPIENT LOCATION
GROUP TRANSFERRED
Customer Data All types held Staff and Strictly to the extent necessary to Northern Ireland,
employees provide our Service Bulgaria
Customer’s Data
Subject Data
All types held Host Service Store data USA
Provider
All types held If we are under a duty to disclose or Currently unknown
share Personal Data in order to
comply with any legal obligation, or
in order to enforce or apply our
terms of use and other agreements
or to protect the operation of our
website, or the rights, property, or
safety of us, our customers, or
others.
All types held Buyer if we sell, transfer or merge parts of Currently unknown
our business or our assets. If a
change happens to our business,
then the new owners will only be
entitled to use Personal Data in
accordance with the provisions set
out in this privacy notice.
Credit Card Stripe Credit card transactions Ireland
information
All types held Intercom Providing help desk and email USA
services for the Software and the
Service
All types held Baremetrics Providing financial planning service USA
If you have any questions about who your data might be transferred to please send us an email kevin@beacon.by
7. WHAT SECURITY PROCEDURES DO YOU HAVE IN PLACE?
7.1 We implement robust security procedures to safeguard the data we hold.
7.2 There are some steps you can take to help make sure that your data is protected. For example:
(a) if you are contacting us with a query or complaint, only ever give us your work details rather than your
personal contact details;
(b) if you are sending any financial details or sensitive information, consider sending it in separate emails or
encrypted, password protected documents; and
(c) make sure that you keep any user names and passwords associated with your Service account secure.
8. WHERE DO YOU STORE THE PERSONAL DATA YOU COLLECT?
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PRIVACY NOTICE FOR BEACON PUBLISHING LTD
8.1 Our servers are currently based in USA.
8.2 If you would like further information about where we store your data, please contact us at kevin@beacon.by
9. FOR HOW LONG DO YOU STORE PERSONAL DATA?
Customer Data
9.1. Our retention policy for Customer Data is follows:
(a) we may store data related to transactions for up to 7 years to ensure that we have sufficient records from an
accounting and tax perspective. Any such data retained for a longer period will be anonymised so that an
individual cannot be identified;
(b) we may archive data relating to negotiations, contracts agreed, payments made, disputes raised and your
use of our software for up to 6 years to protect ourselves in the event of a dispute arising between you and
us. Any such data retained for a longer period will be anonymised so that an individual cannot be identified;
(c) we may retain data which is held for marketing purposes until the Data Subject opts out. We will always
include an opt-out in every marketing communication we send out.
(d) we may store aggregate data without limitation (on the basis that no individual can be identified from the
data).
Customer’s Data Subject Data
9.2. Since we hold Customer’s Data Subject Data as a Processor, we will only retain it for as long as you have an account
with the Service. Once that contract terminates, we will securely delete such data within 30 days.
10. WHAT RIGHTS DO I HAVE IN RESPECT OF ANY PERSONAL DATA YOU HOLD ABOUT ME?
10.1 Data Subjects have the following rights in respect of Personal Data relating to them which can be enforced against
whoever is the Controller. This will be us in respect of Customer Data, and you in respect of Customer’s Data Subject
Data:
(a) Right to be informed: the right to be informed about what Personal Data the Controller collects and stores
about you and how it’s used.
(b) Right of access: the right to request a copy of the Personal Data held, as well as confirmation of:
(i) the purposes of the processing;
(ii) the categories of personal data concerned;
(iii) the recipients to whom the personal data has/will be disclosed;
(iv) for how long it will be stored; and
(v) if data wasn’t collected directly from you, information about the source.
(c) Right of rectification: the right to require the Controller to correct any Personal Data held about you which
is inaccurate or incomplete.
(d) Right to be forgotten: in certain circumstances, the right to have the Personal Data held about you erased
from the Controller’s records.
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PRIVACY NOTICE FOR BEACON PUBLISHING LTD
(e) Right to restriction of processing: the right to request the Controller to restrict the processing carried out in
respect of Personal Data relating to you. You might want to do this, for instance, if you think the data held by
the Controller is inaccurate and you would like to restrict processing the data has been reviewed and updated
if necessary.
(f) Right of portability: the right to have the Personal Data held by the Controller about you transferred to
another organisation, to the extent it was provided in a structured, commonly used and machine-readable
format.
(g) Right to object to direct marketing: the right to object where processing is carried out for direct marketing
purposes (including profiling in connection with that purpose.
(h) Right to object to automated processing: the right not to be subject to a decision based solely on automated
processing (including profiling) which produces legal effects (or other similar significant effects) on you.
10.2 If you want to avail of any of these rights, you should contact us immediately at kevin@beacon.by If you do contact
us with a request, we will also need evidence that you are who you say you are to ensure compliance with data
protection legislation.
11. WHAT HAPPENS IF I NO LONGER WANT YOU TO PROCESS PERSONAL DATA ABOUT ME?
11.1 You may notify us at any time that you no longer want us to process Personal Data about you for particular purposes.
or for any purposes whatsoever. This may have an impact on the services you receive from us. For example, if you
ask us to stop processing Personal Data about you, you will no longer be able to access Software since we will not
be able to identify you.
11.2 A request to stop receiving direct marketing communications will not impact your access to Software.
12. WHO DO I COMPLAIN TO IF I’M NOT HAPPY WITH HOW YOU PROCESS PERSONAL DATA ABOUT ME?
12.1 If you have any questions or concerns about how we are using Personal Data about you, please contact our Data
Protection Officer immediately at our registered address (see paragraph 1.1 above) or by email to
kevin@beacon.by .
12.2 If you wish to make a complaint about how we have handled Personal Data about you, you may lodge a complaint
with the Information Commissioner’s Office by following this link: https://ico.org.uk/concerns/.
13. WHAT DO ALL OF THE DEFINED TERMS IN THIS PRIVACY NOTICE MEAN?
13.1 Throughout this notice you’ll see a lot of defined terms (which you can recognise because they’re capitalised). Where
possible, we’ve tried to define them as we go, but we thought it might be useful to have a glossary at the end for
you. Anywhere in this notice you see the following terms, they’ll have the following meanings:
Customer Data means Personal Data about you;
Customer’s Data Subject means any individual whose Personal Data is contained in any content is uploaded by
you as a Customer into the Software;
Customer’s Data Subject Data means the Personal Data of any Customer’s Data Subject;
Controller is a legal term set out in the General Data Protection Regulation (GDPR), it means the party responsible
for deciding what Personal Data to collect and how to use it;
Data Subject means the individual who can be identified from any Personal Data;
Software means our cloud-based software tool which we use to provide our Service;
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PRIVACY NOTICE FOR BEACON PUBLISHING LTD
Personal Data means data which can be used to identify a living individual. This could be a name and address or it
could be a number of details which when taken together make it possible to work out who the information is
about. It also includes information about the identifiable individual;
Processor is another legal term set out in the GDPR, it means the party who has agreed to process Personal Data
on behalf of the Controller.
Service means the service we provide to you to enable you to transform your internet blog posts into
professionally designed, downloadable content;
we, us, our means Beacon Publishing Ltd of 6 Trossachs Gardens, Belfast, Northern Ireland, BT10 0HX.
Last updated: 25-05-2018.
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