Last updated on Thursday, 28th February 2019 at 19:25
Hello there and welcome to my Privacy Policy! By ‘my’, I’m referring to my website, JaymesPayten.com, which I’ll also call ‘JP’ throughout this wonderfully written and poetic Privacy Policy.
When it comes to privacy and personal data, I leave no stone unturned as your privacy is just as important to me as my own personal privacy. Just to reiterate, I massively respect the privacy of all of my clients, partners, and website visitors, of which there are very few. Can you hear the world’s smallest violin playing in the background?
It’s my aim that you do in fact become a partner or even a paying client, but I digress as this is a Privacy Policy after all.
When it comes to using your personal data, I’m only ever going to be using it in the following ways:
- Selling it on the black market
- Pretending to be you as I stalk Kim Kardashian
- And using it to create fake Facebook accounts
I jest, of course, and in my Privacy Policy, I’ll explain what really happens to your personal data. Until then, here’s some legal dribble that I need to (by law) share with you.
Everything that’s described within the JaymesPayten.com Privacy Policy is extremely consistent with my obligations, and even more importantly, your rights under the law of the Republic of Cyprus. If you didn’t know, I am based in Cyprus, although I am English. Check out my About Me page for more colourful insights.
1.0 Information about me – JaymesPayten.com
1.1 What is Activatorr Limited?
Activatorr Ltd. is our company name, and JaymesPayten.com is our registered brand name, and we do love it, although a few people have (our cleaner and the milkman) have said that it looks like we’re saying something derogatory. We promise you that we’re not. If I’ve thrown you by now saying ‘our’ instead of ‘my’, it’s because I’m one of the shareholders. Sounds interesting doesn’t it? Well it’s not. Look up ASMR on YouTube instead as that’s far more interesting.
1.2 Where is Activatorr Limited based?
Activatorr Ltd. is based on the sunny island of Cyprus, and our registered address is 12 Livadion, Potamia, Nicosia, 2573, Cyprus. The Activatorr Ltd. company registration number is HE 376937.
2.0 What my Privacy Policy covers
I’ve carefully put together this Privacy Policy so that you can better understand how I use your personal data. But that’s not all! I’m also going to tell you all the dark and mischievous things I’m going to do with your data once I’ve collected it. It doesn’t involve me stalking Kim.
2.1 Talking about third-party apps
I’ll be letting you know how your data is collected by my site JaymesPayten.com as well as the third-party apps I use on my website. I also collect data via offline ways too. I can picture the Gen Z’s reading this looking bemused at what the word ‘offline’ means.
I’m also going to be telling you how your data is stored by me, and how I process your data and turn it into bacon butties. Mmm, bacon.
2.2 Your rights under law
My Privacy Policy will then go on to explain your rights under the law that relates to your personal data. Remember, as I’m based in sunny Cyprus, I’m using the laws of the Republic of Cyprus. Cyprus is also in the EU, which means JaymesPayten.com needs to be fully GDPR compliant. I’ll get to all that GDPR jazz in just a moment.
3.0 What the heck is personal data?
As I’ve just mentioned, I’m based in the EU, which does nothing for my social life, but does give you some data street cred. It’s best if I take a look at what the EU handbook says with regards to ‘Personal Data’:
‘Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.’
Voilà! That sentence is taken from the General Data Protection Regulation – EU Regulation 2016/679, under the GDPR section. Trust me when we tell you it’s not a page turner.
Let’s simply this for you; personal data is any information about you that allows you to be identified online or offline. When it comes to personal data, I’m definitely talking about obvious stuff such as your full name and contact details. If your personal data stopped there, the world would’ve been an easier place to live in.
Alas, there are more bits and pieces that make up your personal data such as any identification numbers that belong to you, for instance:
- Your passport number
- Your national identity card (if you have one of these beauties. We do in Cyprus)
- Electronic location data
- Any other online identifiers such as your email
- The personal data that I use is set out in Part 5, so get the popcorn ready. Yay!
4.0 What are my rights? “You have rights?” Yes you do
4.1 What is GDPR?
As I mentioned in part 3, GDPR is a big deal in the EU. GDPR is an acronym for General Data Protection Regulation. In this section, I’m going to talk about your rights and give you a quick infomercial on GDPR.
We know what GDPR stands for, but do you know what it is? No? Well let’s get our friends over at Wikipedia tell us:
‘The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union (EU) and the European EconoJPc Area (EEA).’
None the wiser? Let me attempt to simplify it…
If you live in the European Union, your personal data is now protected under GDPR, which is a law. And the kicker? Even if the site you’re visiting isn’t hosted on servers in the EU, you’re still covered by GDPR. Basically, if you’re an EU citizen, you should be feeling warm and fuzzy right about now. The JP Team is predominantly from the UK (that’s me a some of my helpers) but we live in an EU state – Cyprus, which means we’re covered by GDPR.
Let me sum this section up by telling you what rights – under GDPR – you’re given. Before I do that, I’d like to tell you that I will always do everything I can to ensure your rights are upheld. I’m good like that.
4.2 Your rights under GDPR
Okay, so here are your personal data protection rights under GDPR:
- You have the right to be informed about my collection of, and use of your personal data.
- You have every right to access the personal data I hold about you, and in part 10, I dive into that.
- You have the right to restrict or prevent the processing of your personal data.
- You have every right to make changes to your personal data. If, for instance, it’s wrong or simply incomplete, you can get in touch with me using the contact details I’ve added to part 11 of this JaymesPayten.com Privacy Policy.
- You have the right to have your personal data completely and utterly scrubbed from my servers. I do hope that it never comes to that, of course, but nevertheless, you have the right to ask for your details to be removed from my servers.
- You have the right to object to me using your personal data for a specific reason. For instance, I might want to email you, but you might not want to receive an email from me, which would be a crying shame as my emails are damn fine girl. A bit too much? Sue me.
4.3 What is Data Portability?
The right to data portability. ‘Go on JP, do your best to explain what that means!’ Okay, I will. ‘Data Portability’ is when you’ve provided your personal data to me directly, either via a form or because you’ve physically filled in a coupon; not that I would ever give out coupons.
I then use your data with your consent or for the performance of a contract, and that data is processed using some sort of automation or by an automated means. So by having a right to data portability, it basically means you can ask me for a copy of that personal data so that you can reuse it with another service or business. Oh, and I need to do this for you within one month of you asking me to do it.
You have rights that relate to automated decision-making and profiling. Check out the awesome part 6 of this Privacy Policy as it explains how I use your personal data for automated decision-making and profiling.
Want to know more about my use of your personal data? Simply get in touch with me using the contact details I’ve added to part 11. If you’re in Cyprus and you’re reading this, well done you!
You can find out more about your personal data rights by visiting your local Citizens Advice Bureau (they’re called Citizens Service Centres here in Cyprus, or Κέντρο Εξυπηρέτησης του Πολίτη. What, you thought I wouldn’t use any Greek in my Privacy Policy? Here’s a plate, break it).
Before I wrap up part 4, I do need to tell you that if you have any cause for complaint about my use of your personal data, you’re free to file a complaint with the GDPR Officer at your local Citizens Advice Bureau or Citizen Service Centre. I personally hope you never have to take those measures, but it’s your right to do so. What you can’t do is complain about the state of this Privacy Policy. Well, technically you can, and to be honest, I’d like to see how I’d be reprimanded.
5.0 What personal data do I collect here at JaymesPayten.com?
When it comes to collecting your personal data, the data I’m collecting from you really does depend on the relationship you have with me. For instance, if you’re a client and I’m creating awesome Content Marketing for you, the personal data I’m getting from you is quite different than the data I’m getting from a website visitor who peruses through JaymesPayten.com, but never fills in a form on my site or enters their details on a landing page.
5.1 The list of personal data I store
Here’s an extensive list of the personal data I’ll collect and store:
- Your full name
- Your email address
- Your business name
- Your job title
- Your professional experience in the form of the content that’s within any CV you upload to my website
- Cookies
6. How do you use my personal data?
Under GDPR, it’s really important for me to have a lawful basis for using your personal data. Plus, it takes time and resources to store your data, so I’m storing it because I need it, not just because I want to. One of the main reasons I store and use your personal data is so that I can reach out to you and service your Content Marketing and general Marketing needs. It’s also in my interests to use your data so that I can, for example, contact you and give you amazing insights into the latest Content Marketing trends that will help boost your sales.
6.1 How your personal data might be used by me
‘I use your personal data in weird and mysterious way’, said no one, ever, at JaymesPayten.com. I’m really not into using your personal data in shady ways as it’s simply not in my or your interests to do so.
Here’s how your personal data might be used by JaymesPayten.com:
- Your personal data allows me to manage your partner or client account.
- It allows me to provide you with awesome Content Marketing services. I use your personal details so that I can enter into a contract with you, if you want to, that is.
- I use your data to personalise and tailor my products or services for you. I’ll try my best to offer you Content Marketing services and products that you actually need and that’ll help you and your business flourish. I’m not into wasting your time, so it wouldn’t be great if I offered you products and services that you simply weren’t interested in.
- I use your data to communicate with you via email and even the phone (via a standard call, SMS or WhatsApp). I certainly don’t have a call centre or a sales team, so you needn’t worry about me or anyone from JaymesPayten.com calling you and trying to sell you things you don’t need.When I do email you, it’s because you’ve opted-in to receiving propaganda, I mean emails from me. You can unsubscribe or opt-out by clicking on the ‘unsubscribe’ link, which is at the bottom of every email I send out. You can also email me at hello@jaymespayten.com and ask to be taken off our email subscription list.
- Every now and then, and with your permission and/ or where I’m permitted by law, I might use your personal data for marketing purposes, after all, JaymesPayten.com is an awesome marketing agency in its own right. By ‘marketing purposes’, I’m talking about contacting you by email with news, info, as well as offers on my latest Content Marketing products or services.
6.2 Spam is bad, and incredibly boring…
What I will never do – and this is a promise – is send you any spammy emails, as spam isn’t marketing, and it’s not how I roll.
I don’t sell email lists or loan lists of emails out as that sort of defeats the purpose of Content Marketing. Another bit of good news is that I’m always looking at new and improved ways on how to better protect your personal data rights. As you’ve noticed (if you’ve got this far in my Privacy Policy) I comply with my obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations of 2003, plus you’ll always have the opportunity to opt-out of anything I’m offering.
Even though the JaymesPayten.com Team is filled with people (2, or 3 people when it’s sunny) that have university degrees, I still need to use automated systems to help me carry out all sorts of client profiling, such as Google Analytics, HelpScout, Insightly, and Survey Monkey.
6.3 Automated profiling
If you’d prefer a human touch to profiling yourself, under GDPR, you’re given the right to do so. All you need to do is contact me using the details in part 11.
- The following automated profiling may take place:
- If you’ve opted-in to receive cookies via https://www.jaymespayten.com, or via any of my landing pages landing pages (all my LPs are on a sub-domain, e.g. https://reg.jaymespayten.com, then, depending on how you interact with my site, you may see targeted JaymesPayten.com ads.
- You might see text and display ads on search engines such as Google’s and Bing’s search results pages.
- In other cases, you might see my banner ads on a whole host of third-party websites too. My banner ads are served via the Google Display Network, Bing Display Network, Outbrain, Taboola, and AdRoll on websites which have opted to display JP banner ads. I know that I shouldn’t be advertising my wares on my own Privacy Policy, but when it comes to PPC/ SEM services, you’ll find it hard to find a better agency that can get you what you need. It makes sense that I use my PPC Jedi skills on my clients and even potential clients.
7.0 How long do you get to keep my personal data, eh JaymesPayten.com?
A long time ago in a galaxy that wasn’t far away at all, the previous data protections acts allowed companies to store your data for what seemed to be a million years.
Under GDPR, I’ll only keep your personal data for as long as I need to, with the duration depending on the reason I collected your personal data in the first place.
7.1 Keeping your personal data
To better understand this, let’s look at how long I get to keep your data, and for what reason:
- Cookies will be kept for a maximum of 540 days, but this duration can be reset if you visit my website or partner websites that are used as sub-domains, e.g. https://reg.jaymespayten.com.
- When it comes to email addresses, I store them for as long as I think they’re useful, or until you opt-out or unsubscribe.
8.0 Where do you store my personal data and how do you store it?
In this action-packed section, I’ll show to you where I store your personal data, as well as show you how I store it.
8.1 Storing your data in the EEA
Wherever possible, I’ll only store or transfer your personal data within the EEA, or better known as the European Economic Area. The EEA is made up of all EU member states, as well as Norway, Iceland, and Liechtenstein.
If I store your data on servers within the EEA, your personal data qualifies under GDPR, or to equivalent standards by law.
8.2 Storing your data outside of the EEA
There’s a chance that I’ll transfer your data to the United States of America, and I’ll only transfer your data to a third-party based in the USA if they’re part of the EU-US Privacy Shield.
You needn’t be worried about me transferring your data to a third-party in the USA, as the third-party companies I use provide data protection to the same standards as me. If you want to read more about this, check out this info from the European Commission, which discusses the transference of personal data.
If you’d like to more about how I transfer your personal data to third-parties, my contact details are listed in part 11, and throughout this site.
8.3 More info on your personal data
Here’s some more info you might be interested in:
- I only retain your personal data for as long as is necessary, and I won’t hold onto it for a second longer than is required.
- Access to personal data is restricted to specific team members here at JaymesPayten.com. I certainly don’t provide access to your personal data to every member of staff, but rather segment the team into user groups and grant specific access to those in my team who need to access your data.
- I keep a record of exactly what personal data I store and process.
9. Does JaymesPayten.com share my personal data?
Yes, but don’t be alarmed as we (I’ll change from the singular tense to the plural as from this point on, my team gets involved, as well as me) only share your personal data with other companies in our group (Activatorr Ltd) for marketing purposes. We’ll only get in touch with you if we feel one of Activatorr’s brands can help you or your company grow.
9.1 Sharing your personal data with third-party companies
There is a chance of us signing contracts with third-parties on our behalf. ‘What!?’Don’t stress. The companies we partner with include payment processing, delivery, and marketing companies.
We’ve worked with these companies for years and I personally trust them and can vouch for them. I do need to tell you that some of these third-party companies might need access to some or all of your personal data that we’ve stored.
9.2 The list of companies JaymesPayten.com shares your personal data with
Here’s a list of the companies we’re happy to partner with:
- Giphy.com – we may share your personal data for online marketing reasons.
- Google – we may share your personal data for online marketing reasons.
- Twitter – we may share your personal data for online marketing reasons.
- LinkedIn – we may share your personal data for online marketing reasons.
- Facebook – we may share your personal data for online marketing reasons.
- Microsoft – we may share your personal data for online marketing reasons.
- MailChimp – we may share your personal data such as your first name and email address so that we can add you to any mailing lists that you’ve opted into.
- Silverpop – same as MailChimp really as Silverpop is an email service we use.
- Sendgrid – same as MailChimp and Silverpop as Sendgrid is an email service.
- Tealium – we may share your personal data for online marketing reasons.
If one of the above third-party companies we partner with need some or all of your personal data, we’ll take the necessary steps to make sure your personal data is handled securely, but more importantly, in accordance with your rights, our obligations, and the third party’s obligations under the law, as we discussed in Part 8.
If we need to transfer any of your personal data outside of the EEA, we’ll take suitable steps to ensure that all your personal data is treated just as safely and securely as it would be within Cyprus and under the GDPR.
Remember, your personal data is paramount to everyone here at JP and we would never transfer it to any entity unless we were 100% sure that they abided by all the known personal data laws.
In some cases, we might be legally required to share your personal data, e.g. if we’re involved in a legal case. For instance, we might need to hand over your personal data if we receive a court order, or an order from a government authority.
We will always battle to hold onto your personal data and will only ever hand it over if it’s absolutely necessary.
10. How can I access my personal data if you’re storing it?
10.1 What is SAR?
If you’re curious as to your own personal data that I’ve stored, you can ask me for a SAR, or Subject Access Request. Me or one of the boffins here at JP will send you over a copy of your personal data within 28 days of your SAR. If there are any difficulties in us issuing you the SAR, we’ll be in touch and let you know. To activate a SAR, check out our contact details in part 11.
We won’t charge you for issuing a SAR, unless you overdo it and ask us to issue a SAR repeatedly. If you do this, there is a chance that we will charge you as it takes time for us to perform a SAR. If we do take the decision to charge you, we’ll let you know before you receive the SAR.
11. How do I contact JaymesPayten.com about my personal data?
You can reach out to me personally with regards to your personal data and data protection by emailing me using the following details:
- Email address: hello@jaymespayten.com.
- Telephone number: +44 20 3289 9505.
- Postal Address: 12 Livadion, Potamia, Nicosia, 2573, Cyprus.
12. What happens if you make changes to your Privacy Policy?
As time goes by, certain laws and procedures change, and those changes might be reflected within this Privacy Policy. Don’t forget that GDPR is pretty new; with the GDPR law coming in on 25th May 2018, so there’s a pretty big chance that an update to GDPR law will happen.
12.1 Where you can find our updated Privacy Policy
If I do update this Privacy Policy, I’ll simply update it here, on the JP website – https://www.jaymespayten.com/policies/privacy-policy, and will also email you, letting you know that I’ve got a newer version.