It is effective from 12 September 2019
● what information we collect and when we collect it
● what we do with it and how we keep it secure
● what we use it for; and
● how you can control our use of it.
We operate under the General Data Protection Regulation (GDPR), a European Union regulation, effective from 25 May 2018. GDPR is designed to improve the data security and privacy of European citizens. You can read more about it on Wikipedia. In short, it is designed to ensure that your data is safe, and that you can access and control it. It gives you greater security, transparency, and control of your personal data online, something we are fully committed to.
We collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on your engagement with us and how you use any of our products or services. This means we collect and use your information only where:
● we need it to provide you with our products and services, including to operate them, provide support and to protect their safety and security;
● it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our products and services and to protect our legal rights and interests; or
● we need to process your data to comply with a legal obligation.
What information we collect and when we collect it
We may collect information about you whenever you engage with us, including when you subscribe to one of our mailing lists, or place an order for our products or services and/or manage your account with us. We also collect information when you voluntarily provide feedback or complete customer surveys. Website usage information may also be collected when you are on our website, using cookies (which we talk more about later in this document).
We may collect the following information:
● name and contact information e.g. email address
● demographic information e.g. location
● other information e.g. preferences and interests – relevant to our products and services, market research and/or offers we may be able to provide
When visitors leave comments on the site 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 on the website.
We only ever gather the information we require to understand your needs and provide you with the highest quality products and services.
Embedded content from other websites
Articles on this site 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.
What we do with the information
We use the information we gather for the following reasons:
● internal record keeping
● improving our products and services
● periodically sending emails about our products and services, special offers or other information which we genuinely think you may find interesting. You are always able to opt out at any time
● we may also use your information to contact you for market research purposes or to get feedback in order to improve our products and services. You are always able to opt out at any time
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. We also review our contracts with vendors and partners to make sure they are also compliant, and can give us the guarantees on privacy and data protection that we require, such as the EU-US Privacy Shield framework.
Website analytics and cookies
We use web analytics to learn how our website is performing and to help us to continually improve the site’s functionality. Any analytics data that is collected, processed and stored while you are on our website is aggregated, anonymous, secure and kept confidential.
Links to other websites
Controlling your personal information
Whenever you are asked to provide us with any of your information, either electronically or in person, this is always your choice and we will always keep your information confidential. You may change your mind at any time by updating your contact preferences or unsubscribing using the links we include in all direct marketing emails.
We will not sell your personal information.
We will not share your personal information with third parties unless we have your permission or are required by law to do so.
Access to your information and correction
You may request details of personal information which we hold about you by emailing firstname.lastname@example.org or writing to us at: TCT Literary Agency, The Melting Pot, 5 Rose Street, Edinburgh EH2 2PR.
We will always do our best to ensure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate, and we will promptly correct any information found to be incorrect.
This feature only records activities of a site’s registered users, and the retention duration of activity data will depend on the site’s plan and activity type.
Data Used: To deliver this functionality and record activities around site management, the following information is captured: user email address, user role, user login, user display name, WordPress.com and local user IDs, the activity to be recorded, the WordPress.com-connected site ID of the site on which the activity takes place, the site’s Jetpack version, and the timestamp of the activity. Some activities may also include the actor’s IP address (login attempts, for example) and user agent.
Activity Tracked: Login attempts/actions, post and page update and publish actions, comment/pingback submission and management actions, plugin and theme management actions, widget updates, user management actions, and the modification of other various site settings and options. Retention duration of activity data depends on the site’s plan and activity type. See the complete list of currently-recorded activities (along with retention information).
Data Synced (?): Successful and failed login attempts, which will include the actor’s IP address and user agent.
Image views are only recorded if the site owner, has explicitly enabled image view stats tracking for this feature via the jetpack_enable_carousel_stats filter.
Data Used: If image view tracking is enabled, the following information is used: IP address, WordPress.com user ID (if logged in), WordPress.com username (if logged in), user agent, visiting URL, referring URL, timestamp of event, browser language, country code.
Activity Tracked: Image views.
This feature is only accessible to users logged in to WordPress.com.
Data Used: In order to process a comment like, the following information is used: WordPress.com user ID/username (you must be logged in to use this feature), the local site-specific user ID (if the user is signed in to the site on which the like occurred), and a true/false data point that tells us if the user liked a specific comment. If you perform a like action from one of our mobile apps, some additional information is used to track the activity: IP address, user agent, timestamp of event, blog ID, browser language, country code, and device info.
Activity Tracked: Comment likes.
Data Used: Please refer to the appropriate Google Analytics documentation for the specific type of data it collects. For sites running WooCommerce (also owned by Automattic) and this feature simultaneously and having all purchase tracking explicitly enabled, purchase events will send Google Analytics the following information: order number, product id and name, product category, total cost, and quantity of items purchased. Google Analytics does offer IP anonymization, which can be enabled by the site owner.
Activity Tracked: This feature sends page view events (and potentially video play events) over to Google Analytics for consumption. For sites running WooCommerce-powered stores, some additional events are also sent to Google Analytics: shopping cart additions and removals, product listing views and clicks, product detail views, and purchases. Tracking for each specific WooCommerce event needs to be enabled by the site owner.
Data Used: Commenter’s name, email address, and site URL (if provided via the comment form), timestamp, and IP address. Additionally, a jetpack.wordpress.com IFrame receives the following data: WordPress.com blog ID attached to the site, ID of the post on which the comment is being submitted, commenter’s local user ID (if available), commenter’s local username (if available), commenter’s site URL (if available), MD5 hash of the commenter’s email address (if available), and the comment content. If Akismet (also owned by Automattic) is enabled on the site, the following information is sent to the service for the sole purpose of spam checking: commenter’s name, email address, site URL, IP address, and user agent.
Activity Tracked: The comment author’s name, email address, and site URL (if provided during the comment submission) are stored in cookies. Learn more about these cookies.
Data Synced (?): All data and metadata (see above) associated with comments. This includes the status of the comment and, if Akismet is enabled on the site, whether or not it was classified as spam by Akismet.
This feature is only accessible to users logged in to WordPress.com.
Data Used: In order to process a post like action, the following information is used: IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID (on which the post was liked), post ID (of the post that was liked), user agent, timestamp of event, browser language, country code.
Activity Tracked: Post likes.
Data Used: A visitor’s preference on viewing the mobile version of a site.
Activity Tracked: A cookie (akm_mobile) is stored for 3.5 days to remember whether or not a visitor of the site wishes to view its mobile version. Learn more about this cookie.
This feature is only accessible to registered users of the site who are logged in to WordPress.com.
Data Used: IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code. Some visitor-related information or activity may be sent to the site owner via this feature. This may include: email address, WordPress.com username, site URL, email address, comment content, follow actions, etc.
Activity Tracked: Sending notifications (i.e. when we send a notification to a particular user), opening notifications (i.e. when a user opens a notification that they receive), performing an action from within the notification panel (e.g. liking a comment or marking a comment as spam), and clicking on any link from within the notification panel/interface.
Data Used: In order to check login activity and potentially block fraudulent attempts, the following information is used: attempting user’s IP address, attempting user’s email address/username (i.e. according to the value they were attempting to use during the login process), and all IP-related HTTP headers attached to the attempting user.
Activity Tracked: Failed login attempts (these include IP address and user agent). We also set a cookie (jpp_math_pass) for 1 day to remember if/when a user has successfully completed a math captcha to prove that they’re a real human. Learn more about this cookie.
Data Synced (?): Failed login attempts, which contain the user’s IP address, attempted username or email address, and user agent information.
Data Used: To initiate and process subscriptions, the following information is used: subscriber’s email address and the ID of the post or comment (depending on the specific subscription being processed). In the event of a new subscription being initiated, we also collect some basic server data, including all of the subscribing user’s HTTP request headers, the IP address from which the subscribing user is viewing the page, and the URI which was given in order to access the page (REQUEST_URI and DOCUMENT_URI). This server data used for the exclusive purpose of monitoring and preventing abuse and spam.
Activity Tracked: Functionality cookies are set for a duration of 347 days to remember a visitor’s blog and post subscription choices if, in fact, they have an active subscription.
WordPress.com Secure Sign On
This feature is only accessible to registered users of the site with WordPress.com accounts.
Data Used: User ID (local site and WordPress.com), role (e.g. administrator), email address, username and display name. Additionally, for activity tracking (see below): IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code.
Activity Tracked: The following usage events are recorded: starting the login process, completing the login process, failing the login process, successfully being redirected after login, and failing to be redirected after login. Several functionality cookies are also set, and these are detailed explicitly in our Cookie documentation.
Data Synced (?): The user ID and role of any user who successfully signed in via this feature.
Data Used: IP address, WordPress.com user ID (if logged in), WordPress.com username (if logged in), user agent, visiting URL, referring URL, timestamp of event, browser language, country code. Important: The site owner does not have access to any of this information via this feature. For example, a site owner can see that a specific post has 285 views, but he/she cannot see which specific users/accounts viewed that post. Stats logs — containing visitor IP addresses and WordPress.com usernames (if available) — are retained by Automattic for 28 days and are used for the sole purpose of powering this feature.
This feature is only accessible to registered users of the site who are also logged in to WordPress.com.
Data Used: Gravatar image URL of the logged-in user in order to display it in the toolbar and the WordPress.com user ID of the logged-in user. Additionally, for activity tracking (detailed below): IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code.
Activity Tracked: Click actions within the toolbar.
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