Who we are
This website is owned and controlled by Ajar Group Limited (Ajar Group). Websites operated by Ajar Group include managingdigital.com, danwarfield.io, ccceurope.com, jnwarfield.com and ajarpublishing.com.
CCPA means the California Consumer Privacy Act.
The GDPR means the General Data Protection Regulation of the European Union.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Ajar Group Limited.
Service means this website and any of its parts including without limitation blog posts, comments, data collection forms, media such as photos and videos.
Business, for the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
Consumer, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. For the purpose of the GDPR, the Company is the Data Controller. We have also appointed a privacy representative in the European Union.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under the GDPR, you can be referred to as the Data Subject or as the User as you are the individual using the Service.
Account means a unique account created for you to access our Service or parts of our Service.
Personal Data is any information that relates to an identified or identifiable individual. For the purposes of the GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
What personal data we collect and why we collect it
When visitors leave comments on the Website we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images they can see on the website.
Embedded content from other websites
Articles on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
We may ask you to provide personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City, Country
- Bank account information in order to pay for products and/or services within the Service
- Usage Data
When you pay for a product and/or a service via bank transfer, We may ask you to provide information to facilitate this transaction and to verify your identity. Such information may include, without limitation:
- Date of birth
- Passport, National ID card or other proof of identity
- Bank card statement
- Other information linking you to an address
Usage Data is collected automatically when using the Service.
Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.
Tracking Technologies and Cookies
If you leave a comment on our website you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service.
Types of Cookies
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
We may use both session and persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and We only use these Cookies to provide you with those services.
- Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
- Tracking and Performance Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.
- Targeting and Advertising Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies track your browsing habits to enable Us to show advertising which is more likely to be of interest to you. These Cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with Our permission, third party advertisers can place Cookies to enable them to show adverts which We think will be relevant to your interests while you are on third party websites.
Use of your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with Us through the Service.
- To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
- To manage your requests: To attend and manage your requests to Us.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
We may share your personal information in the following situations:
- With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to you to help support and maintain Our Service, to advertise on third party websites to you after you visited our Service, for payment processing, to contact you.
- For Business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
- With Business partners: We may share your information with Our business partners to offer you certain products, services or promotions.
- With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see you name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
Retention of your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their own personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Transfer of your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Disclosure of your Personal Data
Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of your Personal Data
The security of your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of your Personal Data
Service Providers have access to your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service providers to monitor and analyze the use of our Service.
We may use Service providers to show advertisements to you to help support and maintain Our Service.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. you may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to you.
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
When you use Our Service to pay a product and/or service via bank transfer, We may ask you to provide information to facilitate this transaction and to verify your identity.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: you have given your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
What rights you have over your data
If you have an account on this website, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. you can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.
- Request access to your Personal Data. The right to access, update or delete the information We have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Us to assist you. This also enables you to receive a copy of the Personal Data We hold about you.
- Request correction of the Personal Data that We hold about you. you have the right to to have any incomplete or inaccurate information We hold about you corrected.
- Object to processing of your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. you also have the right to object where We are processing your Personal Data for direct marketing purposes.
- Request erasure of your Personal Data. you have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you.
- Withdraw your consent. you have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, We may not be able to provide you with access to certain specific functionalities of the Service.
Exercising of your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, We will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
Representation for data subjects in the EU
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/15034368
Your Rights under the CCPA
- The right to notice. you must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request. The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
- The right to say no to the sale of Personal Data. you also have the right to ask the Company not to sell your Personal Data to third parties. you can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.
- The right to know about your Personal Data. you have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about you
- The right to delete Personal Data. you also have the right to request the deletion of your Personal Data that have been collected in the past 12 months.
- The right not to be discriminated against. you have the right not to be discriminated against for exercising any of your Consumer’s rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can email or call us or visit our “Do Not Sell My Personal Information” section or web page.
The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable, necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA law.
If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser you use. you may need to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service, which may take the form of:
- “Cookie Consent” notice banner
- “CCPA Opt-out” notice banner
- “Do Not Sell My Personal Information” notice banner
- “Do Not Sell My Personal Information” link
Where this is available, the opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
You may also opt out by writing to us.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online websites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact Us using the contact information provided below, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services.
- By email: [email protected]
- By mail: Ajar Group Limited, 37 Great Pulteney Street, Bath BA2 4DA, United Kingdom