Privacy Policy

Privacy Policy

Governing Principles

In all my relationships and commercial transactions (whether contractual, moral or social) I strive to ensure that fairness and reasonableness prevails in all circumstances.

I expect all people to behave legally, decently, fairly and ethically in all circumstances. This expectation includes, but is not restricted to compliance with appropriate professional regulations, standards and guidelines.

I am committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data I collect from you, or that you provide to me, might be processed by me. Please read the following carefully to understand my views and practices regarding our personal data and how I might treat it.

For the purpose of the Data Protection Act 1998 (the “Act”) and the General Data Protection Regulation (EU) 2016/679 (GDPR), the data controller is Michael Mainelli at 41 Lothbury, London EC2R 7HG.

Information I Collect

I might collect and process the following data about you:

  • information that you provide by registering and/or filling in forms on my site mainelli.org (“my site”). For the avoidance of doubt, such activity by you unambiguously comprises opt-in consent for me to use that data under the terms of this privacy agreement. For example, I might ask you to complete surveys that I use for research purposes, although you do not have to respond;
  • I might also ask you for information when you report a problem with my site;
  • if you contact me, I might keep a record of that correspondence;
  • details of your visits to my site and the resources you access, even if I do not hold any personal data about you.

Storing Our Data

Your personal data shall not be transferred to a country or territory outside the European Economic Area (“EEA”) unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. Subject to the preceding constraint, our personal data might be processed by people operating outside the EEA. By submitting your personal data on-line, you agree to this transfer, storing or processing. I will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

The transmission of information via the internet is not completely secure. I shall do my best to protect your personal data, but I cannot guarantee the security of our data transmitted to my site; any transmission is at our own risk. Once I have received your information, I will use strict procedures and security features to try to prevent unauthorised access.

Using Our On-Line Information

I might use information held about you in the following ways:

  • to ensure that content from my site is presented in the most effective manner for you and for your computer;
  • to contact you where you have requested information from me or have reported a problem with my site; and
  • to notify you about changes to my service.

My site might, from time to time, contain links to and from the websites of my partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that I do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Disclosure

I might disclose your personal information to third parties in the event that my assets are acquired by a third party; if I am under a duty to disclose or share our personal data in order to comply with any legal obligation, or in order to enforce or apply my terms and conditions of use and other agreements; or to protect the rights, property, or safety of me  or others.

Legal Basis For Processing

I might hold personal information about you for one or more of the following legal bases for processing:

Consent: the individual has given clear consent for you to process their personal data for a specific purpose – most of the personal information I hold is held on this legal basis. For example, your use of my on-line facilities comprise clear consent as documented in this privacy policy.

Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract – if I have proactively contacted you, it is possible that you have or someone in our organization has provided your details for this legal basis.

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. – if I have proactively contacted you, it is possible that you have or someone connected with you has provided me with your details for this legal basis. I am a research-based person whose objective is to promote societal advance; this results in my legitimate interests being diverse and long-term.

Your Rights

I believe that it is highly unlikely that my use of your data should have any adverse effect on you nor should my use of your data provide you with cause for any legitimate concerns. Nonetheless, I fully endorse the GDPR individual rights and have processes in place to enable you to assert and enforce those rights. This link to the GDPR guidance lists our rights, each of which is a link to a full description of that right.

For example, you have the right to withdraw your consent for me to process your data at any time, by you simply asking to de-register or unsubscribe. As another example, GDPR gives you the right to access information I hold about you. You can exercise these rights, or indeed any of our rights under GDPR by contacting me at michael_mainelli@zyen.com.

If you think there is a problem with the way I am handling your data and/or you are dissatisfied with the way I have tried to address your requests or concerns, you have the right to complain to the Information Commissioner’s Office (ICO) – click here for a link to the relevant part of the ICO web site.

Retention Policy

I continue to hold data for processing while I have a legitimate basis for processing, unless you withdraw consent, at which point I would, within a reasonable time (normally within a few days or weeks) archive the personal data I hold about you. I retain archived data for a minimum of seven years, in many cases indefinitely, unless I receive a legitimate, specific request from an individual who wishes me to remove their personal data from the archive in accordance with their right under GDPR.

Changes to the Privacy Policy

Any changes I make to my privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Feedback

You may send any questions, comments and requests regarding this privacy policy to michael_mainelli@zyen.com.