This is the Privacy & Cookies Policy (the ‘Policy’) of Quality Nonsense Limited, company number 05889123, of 27 Mortimer Street, London W1T 3BL (hereafter ‘QNL’, ‘we’ or ‘us’). This Policy describes the ways in which QNL collects and uses information about you when you use our website at PlaceHolder.com (the “Website”).
QNL may change this Policy at any time in which case we shall notify you of any changes to this Policy by noting this on the Website. The changes will apply to your use of the Website after we have given notice. If you do not wish to accept the new Policy you should not continue to use the Website. If you continue to use the Website after the date on which the change comes into effect, your use of the Website indicates your agreement to be bound by the new Policy.
This Policy was last changed on 20 Jan 2019.
This Policy can be stored or printed using the buttons at the top of this page.
- ICO registration: For the purposes of data protection legislation, QNL is the controller for the processing of your personal data. QNL has notified the Information Commissioner’s Office (“ICO”) of its processing of personal data. The notification indicates what data is processed by QNL and for what purpose, and to which persons or entities the data will be provided. Click here to consult the notification in the public register of the ICO. QNL’s registration number is Z1052643.
- Information which is collected when you use the Website: QNL may collect the following information from you when you use the Website:
a) any information which you enter into the Website when you sign-up to our newsletter (specifically your name and e-mail address), submit any user-generated content (i.e., the information you submit to us when submitting such content), or participate in any chat session;
b) any technical information which we collect from you when you sign up to our newsletter, specifically the web browser that you are using, including its version number, as well as certain location data – namely your country, city, timezone and approximate latitude and longitude of your location;
d) if you sign into your Account using a social network (such as Twitter or Facebook), we may be able to access certain information about you through that social network that you have agreed to make available; for example on Facebook, your Facebook ID, information relating to your friends, profile picture, gender, language, geo-location or the device you are using. You can change what information we access by changing your privacy features on your social networks; and
e) certain data that we obtain via FullContact.com which compiles various publicly available data about you into one dataset for our review and use.
- How the information collected about you when you download and use the Website is used: The information about you described in Clause 2 may be used by QNL as follows:
a) the information in 2(a) and (b) is used to provide the newsletter that you have requested to you or, in the case of any user-generated content, for us to display such user-generated content on the website together with e.g., your name showing you as the author of such review, or, in the case of the chat service, to answer you query made via such chat service;
b) the information in 2(c) enables QNL to undertake administrative tasks in relation to the management of the Website, to provide technical support and troubleshooting, and to tweak, tune and facilitate the improvement of the Website;
c) the information in 2(d) and (e) enables QNL to compile a more comprehensive picture of the Website users and to be able to best serve users of the Website in doing so;
d) your e-mail address may be used to (subject to you having provided your express consent when registering or us otherwise being permitted to do so via applicable data protection and direct marketing legislation) send e-newsletters relating to our latest developments and events, links to content that we think you will like, promotional offers, discounts and loyalty rewards;
e) all of the information in Clause 2 may be used by us to suggest appropriate Facebook groups or other community groups that you might be interested in, you are able to opt-out of such personalised advertising at any time by clicking here and following the instructions;
f) all of the information in Clause 2 is used to retarget adverts such as Google advertisements or Facebook advertisements appropriately, you are able to opt-out of such personalised advertising at any time by clicking here or the link above and following the instructions;
g) all of the information in Clause 2 is used to audit IP addresses and user behaviour in order to prevent abuse; and
h) all of the information set out in Clause 2 is shared with third parties as described in Clause 5 below.
- Ground for processing: QNL relies on the legitimate interests processing ground to collect the information set out in clause 2, with the exception of that information set out in 2(a) for which QNL relies on consent (as it is your choice whether to ask for a newsletter, participate in a chat and/or submit any user-generated content). It is in QNL’s legitimate interests to collect such items of personal data listed in 2(b) to (e) above because this is necessary in order to provide and improve the services that it offers to you and to make the Website a profitable commercial offering. The items of personal data collected are, in being limited to “business card” type data, not of a nature whereby your rights and freedoms as a data subject are outweighed by such data collection.
- Sharing information with third parties: QNL shall not pass your information to any third party (other than as described in this clause). Your information may, subject to QNL’s obligations to comply with applicable data protection legislation, be shared with the following third parties:
a) various affiliate partners;
b) QNL’s advertising partners such as Google Adsense and Amazon Associates;
c) QNL’s hosting providers – Linode and Amazon AWS;
d) QNL’s analytics partners such as Google, HotJar and VWO;
e) QNL’s support solutions providers such as The Chat Shop, LiveChat, Inc. and HelpScout;
f) QNL’s e-mail marketing provider, Aweber which processes the Newsletter Data;
g) other ancillary social media and other tools such as Facebook, Twitter, MaxMind and Fullcontact.com;
h) QNL’s back-up provider;
i) other providers for QNL’s internal processing (such as Google G-Suite), lead generation services, payment processing services, content delivery services and its survey/quiz provider;
j) having taken precautions to maintain the security of such information, QNL may share this information with its regulator (the ICO);
k) in anonymised form, QNL may share the information with:
ii. any third party, in relation to the sale of some or all QNL’s business, or its assets, or as part of any business restructuring or reorganisation. QNL will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this clause;
iii. data aggregators and platform providers as part of an analysis of user metrics or sales performance; or
iv. law enforcement agencies in compliance with law enforcement.
- Links to third party websites and third party adverts: QNL is not responsible for the privacy policies and practices of other sites even if you access them via the Website. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to your Account from a third party site or via a social network, QNL is not responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
- Security: QNL has implemented technology and policies to safeguard your privacy from unauthorised access and improper use. You may also change your account settings on your social networks to prevent both us and third parties seeing information in relation to you.
- Storage and Data Retention: We retain your personal data as follows: (i) the information you submit to obtain a newsletter is suppressed as soon as you choose to unsubscribe to such newsletter; (ii) the information you submit as user generated content is deleted as soon as you object to such user generated content being continued to be used by us; (iii) the information you submit to participate in a chat is deleted once the purpose for you providing such information has completed and no later than 13 months after you have participated in such chat; and (iv) the other information in 2(b) to (e) will be retained indefinitely because it is not highly sensitive personal data and, in fact, much of the information is non-personally identifiable information and is required for historical reasons to improve the overall user experience. We store all of the information collected on our servers or those of third parties. Where we store your personal data outside the EEA we take steps to ensure that such transfers of your personal data are adequate in accordance with applicable data protection legislation.
b) Disabling Cookies: The use of the cookies described above improves the functionality of the Website and your experience of using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings within the Website, or on your device. Please note that if you do decide to disable cookies you may not be able to access some of the Website, and some of the features of the Website may not function properly. By continuing to use the Website, including using social networking media functionality, you consent to the relevant cookies being set on your device. You can change your browser settings by clicking the appropriate link as follows: Firefox, Chrome, Internet Explorer and/or Safari.
|Performance Cookies||QNL uses persistent cookies and session cookies to, for example, assist in the navigation around the Website, to enhance your use of the Website and to support graphic and video features;||Firefox, Chrome, Internet Explorer and/or Safari|
|Google Analytics||QNL uses Google Analytics to collect: (i) your web browser and version number; (ii) your IP address; (iii) information about your behaviour on our Website including which pages you visit and how long you spend on each page; (iv) your Operating System and version number; (v) your Platform (i.e., whether you are accessing our Website via desktop, mobile or tablet); (vi) your screen resolution; and (vii) any other datapoints as indicated by Google from time to time.||Google Analytics|
- Exercising your rights: You can contact us using the details set out in Clause 11 below if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data.
- QNL Details and GDPR: If at any time you would like to contact QNL about your views on this Policy or any inquiry relating to your personal information, you can do so by completing this form or write to us at “Data Protection Query, Quality Nonsense Limited, 27 Mortimer Street, London W1T 3BL”. You may also submit a complaint to our supervisory authority at any time.