1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors
and customers.

1.2 This policy applies where we are acting as a data controller with
respect to the personal data of our website visitors and customers; in
other words, where we determine the purposes and means of the processing of
that personal data.

1.3 By using our website and agreeing to this policy, you consent to our
use of cookies in accordance with the terms of this policy.

1.4 In this policy, “we”, “us” and “our” refer to Diviniti Publishing Ltd.

2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.

3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address,
geographical location, browser type and version, operating system, referral
source, length of visit, page views and website navigation paths, as well
as information about the timing, frequency and pattern of your service use.
The source of the usage data is Google Analytics and Shopify. This usage
data may be processed for the purposes of analysing the use of the website
and services. The legal basis for this processing is our legitimate
interests, namely monitoring and improving our website and services.

3.3 We may process your account data (“account data“). The
account data may include your name and email address. The source of the
account data is you. The account data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our
legitimate interests, namely the proper administration of our website and
business.

3.4 We may process your information included in your personal profile on
our website (“profile data“). The profile data may include
your name, address, telephone number, email address, profile pictures,
gender, date of birth. The profile data may be processed for the purposes
of enabling and monitoring your use of our website and services. The legal
basis for this processing is our legitimate interests, namely the proper
administration of our website and business.

3.5 We may process information that you post for publication on our website
or through our services (“publication data“). The
publication data may be processed for the purposes of enabling such
publication and administering our website and services. The legal basis for
this processing is our legitimate interests, namely the proper
administration of our website and business.

3.6 We may process information contained in any enquiry you submit to us
regarding goods and/or services (“enquiry data“). The
enquiry data may be processed for the purposes of offering, marketing and
selling relevant goods and/or services to you. The legal basis for this
processing is consent.

3.7 We may process information relating to transactions, including
purchases of goods and services, that you enter into with us and/or through
our website (“transaction data“). The transaction data may
include your contact details, your card details and the transaction
details. The transaction data may be processed for the purpose of supplying
the purchased goods and services and keeping proper records of those
transactions. The legal basis for this processing is the performance of a
contract between you and us and/or taking steps, at your request, to enter
into such a contract and our legitimate interests, namely our interest in
the proper administration of our website and business.

3.8 We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be
processed for the purposes of sending you the relevant notifications and/or
newsletters. The legal basis for this processing is consent.

3.9 We may process information contained in or relating to any
communication that you send to us (“correspondence data“).
The correspondence data may include the communication content and metadata
associated with the communication. Our website will generate the metadata
associated with communications made using the website contact forms. The
correspondence data may be processed for the purposes of communicating with
you and record-keeping. The legal basis for this processing is our
legitimate interests, namely the proper administration of our website and
business and communications with users.

3.10 We may process any of your personal data identified in this policy
where necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court
procedure. The legal basis for this processing is our legitimate interests,
namely the protection and assertion of our legal rights, your legal rights
and the legal rights of others.

3.11 We may process any of your personal data identified in this policy
where necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, or obtaining professional advice. The legal basis
for this processing is our legitimate interests, namely the proper
protection of our business against risks.

3.12 In addition to the specific purposes for which we may process your
personal data set out in this Section 3, we may also process any of your
personal data where such processing is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.

3.13 Please do not supply any other person’s personal data to us, unless we
prompt you to do so.

4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and
all its subsidiaries) insofar as reasonably necessary for the purposes, and
on the legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or
maintaining insurance coverage, managing risks, obtaining professional
advice, or the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure.

4.3 We may disclose notification data to our supplier
iContact (https://www.icontact.com) insofar as reasonably necessary for us
to manage and organise our mailing list and newsletters. You can find
information about iContact’s privacy policies and practices at

https://www.icontact.com/legal/privacy

4.4 Financial transactions relating to our website and services are handled
by our payment services providers (Stripe, Worldpay, Shopify Pay, Apple
Pay, Google Pay, Coinbase and SendOwl). We will share transaction data with
our payment services providers only to the extent necessary for the
purposes of processing your payments, refunding such payments and dealing
with complaints and queries relating to such payments and refunds. You can
find information about the payment services providers’ privacy policies and
practices at:

Apple Pay:
https://support.apple.com/en-gb/HT203027

Shopify:
https://www.shopify.com/legal/privacy

Stripe:
https://stripe.com/gb/privacy

SendOwl:
https://www.sendowl.com/privacy

Google Pay:
https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en

WorldPay:
https://www.worldpay.com/uk/privacy-policy

PayPal:
https://www.paypal.com/en/webapps/mpp/ua/privacy-full

Coinbase:
https://www.coinbase.com/legal/privacy?locale=en

4.5 In addition to the specific disclosures of personal data set out in
this Section 4, we may disclose your personal data where such disclosure is
necessary for compliance with a legal obligation to which we are subject,
or in order to protect your vital interests or the vital interests of
another natural person. We may also disclose your personal data where such
disclosure is necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or
out-of-court procedure.

5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in
which your personal data may be transferred to countries outside the
European Economic Area (EEA).

5.2 The hosting facilities for our website are situated in the United
Kingdom and United States. The European Commission has made an “adequacy
decision” with respect to the data protection laws of each of these
countries. Transfers to each of these countries will be protected by
appropriate safeguards, namely the use of standard data protection clauses
adopted or approved by the European Commission, a copy of which you can
obtain from
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

5.3 You acknowledge that personal data that you submit for publication
through our website or services may be available, via the internet, around
the world. We cannot prevent the use (or misuse) of such personal data by
others.

6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure,
which are designed to help ensure that we comply with our legal obligations
in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be
kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) All data will be retained for a minimum period of 5 years and for a
maximum period of 10 years following its submission to us.

6.4 In some cases it is not possible for us to specify in advance the
periods for which your personal data will be retained. In such cases, we
will determine the period of retention based on the following criteria:

(a) the period of retention of data will be determined based on the need to
login and use our services or access purchased digital products.

6.5 Notwithstanding the other provisions of this Section 6, we may retain
your personal data where such retention is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.

7. Amendments
7.1 We may update this policy from time to time by publishing a new version
on our website.

7.2 You should check this page occasionally to ensure you are happy with
any changes to this policy.

7.3 We may notify you of changes to this policy by email.

8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under
data protection law. Some of the rights are complex, and not all of the
details have been included in our summaries. Accordingly, you should read
the relevant laws and guidance from the regulatory authorities for a full
explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together with
certain additional information. That additional information includes
details of the purposes of the processing, the categories of personal data
concerned and the recipients of the personal data. Providing the rights and
freedoms of others are not affected, we will supply to you a copy of your
personal data. The first copy will be provided free of charge, but
additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you
rectified and, taking into account the purposes of the processing, to have
any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your
personal data without undue delay. Those circumstances include: the
personal data are no longer necessary in relation to the purposes for which
they were collected or otherwise processed; you withdraw consent to
consent-based processing; you object to the processing under certain rules
of applicable data protection law; the processing is for direct marketing
purposes; and the personal data have been unlawfully processed. However,
there are exclusions of the right to erasure. The general exclusions
include where processing is necessary: for exercising the right of freedom
of expression and information; for compliance with a legal obligation; or
for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of
your personal data. Those circumstances are: you contest the accuracy of
the personal data; processing is unlawful but you oppose erasure; we no
longer need the personal data for the purposes of our processing, but you
require personal data for the establishment, exercise or defence of legal
claims; and you have objected to processing, pending the verification of
that objection. Where processing has been restricted on this basis, we may
continue to store your personal data. However, we will only otherwise
process it: with your consent; for the establishment, exercise or defence
of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on
grounds relating to your particular situation, but only to the extent that
the legal basis for the processing is that the processing is necessary for:
the performance of a task carried out in the public interest or in the
exercise of any official authority vested in us; or the purposes of the
legitimate interests pursued by us or by a third party. If you make such an
objection, we will cease to process the personal information unless we can
demonstrate compelling legitimate grounds for the processing which override
your interests, rights and freedoms, or the processing is for the
establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data
for direct marketing purposes (including profiling for direct marketing
purposes). If you make such an objection, we will cease to process your
personal data for this purpose.

8.9 You have the right to object to our processing of your personal data
for scientific or historical research purposes or statistical purposes on
grounds relating to your particular situation, unless the processing is
necessary for the performance of a task carried out for reasons of public
interest.

8.10 To the extent that the legal basis for our processing of your personal
data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to
which you are party or in order to take steps at your request prior to
entering into a contract,

and such processing is carried out by automated means, you have the right
to receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information
infringes data protection laws, you have a legal right to lodge a complaint
with a supervisory authority responsible for data protection. You may do so
in the EU member state of your habitual residence, your place of work or
the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any
time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.

8.13 You may exercise any of your rights in relation to your personal data
by written notice to us.

9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored by the
browser. The identifier is then sent back to the server each time the
browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid
until its set expiry date, unless deleted by the user before the expiry
date; a session cookie, on the other hand, will expire at the end of the
user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally
identifies a user, but personal information that we store about you may be
linked to the information stored in and obtained from cookies.

10. Cookies that we use
10.1 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our
website and as you navigate our website;

(b) status – we use cookies to help us to determine if you are logged into
our website;

(c) personalisation – we use cookies to store information about your
preferences and to personalise the website for you;

(d) security – we use cookies as an element of the security measures used
to protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally;

(e) analysis – we use cookies to help us to analyse the use and performance
of our website and services; and

(f) cookie consent – we use cookies to store your preferences in relation
to the use of cookies more generally. You can manage your cookie settings for this
website by clicking the button below.

Cookie Settings

11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on
your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The
information gathered relating to our website is used to create reports
about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy

11.3 On our sister website www.hypnosisaudio.com we use Shopify. This service uses cookies to operate our ecommerce
store, take orders and manage your account with us. You can view the
privacy policy of this service provider at
https://www.shopify.com/legal/privacy

11.4 On our sister website www.hypnosisaudio.com we use Sendowl. This service uses cookies to operate our digital
download system and secure digital files. You can view the privacy policy
of this service provider at

https://www.sendowl.com/privacy

11.5 On our sister website www.hypnosisaudio.com we use Affilatly. This service uses cookies to operate our affiliate
tracking system. You can view the privacy policy of this service provider
at

https://www.affiliatly.com/terms-of-use-and-privacy-statement.html

11.6 We use iContact. This service uses cookies to operate our mailing list
system and send out our newsletters and offers. We can track, at an
individual level, whether the user has opened and clicked on an email. We
do not use this information at a personal level, rather we use it to
understand open and click rates on our emails to try and improve them. If
you want to be sure that none of your email activity is tracked then you
should opt out of our emails which you can do via the unsubscribe link at
the bottom of every email we send. You can view the privacy policy of this
service provider at

https://www.icontact.com/legal/privacy

11.7 We use social media buttons and Facebook pixels. These cookies are set on your machine by
external websites whose services are used on this site. Cookies of this
type are the sharing buttons across the site allow visitors to share
content onto social networks. Cookies are currently set by Twitter, Google
& Facebook.

In order to implement these buttons and Facebook pixels, and connect them to the relevant
social networks and external sites they may use scripts from domains
outside of our website. You should be aware that these sites are likely to
be collecting information about what you are doing all around the internet,
including on this website.

You should check the respective policies of each of these sites to see how
exactly they use your information and to find out how to opt out, or
delete, such information. You can view the privacy policy of these service
providers at:

Facebook:

https://www.facebook.com/full_data_use_policy


Twitter: https://twitter.com/en/privacy

Google:


https://www.google.com/policies/privacy

11.8 We use WordPress. The Blog and Forum section of this website runs the
popular WordPress CMS and cookies are used to store basic data on your
interactions, and whether you have logged into WordPress. We use a session
cookie to remember your log-in for you if you are a registered user and we
deem these as being strictly necessary to the working of the website. If
these are disabled then various functionality on the site will be broken.
More information on session cookies and what they are used for at

www.allaboutcookies.org/cookies/session-cookies-used-for.html

11.9 If you click a link to our sister website www.hypnosisaudio.com we use
cookies to track the items in your basket as you navigate from page to
page. We also use these cookies to remember who you are when you log in and
register with us. You can view the privacy policy of this service provider
at

https://www.hypnosisaudio.com/pages/privacy

12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from
version to version. You can however obtain up-to-date information about
blocking and deleting cookies via these links:

(a)

https://support.google.com/chrome/answer/95647?hl=en

(Chrome);

(b)

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

(Firefox);

(c)

http://www.opera.com/help/tutorials/security/cookies

(Opera);

(d)

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

(Internet Explorer);

(e)

https://support.apple.com/kb/PH21411

(Safari); and

(f)

https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

(Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of
many websites.

12.3 If you block cookies, you will not be able to use all the features on
our website.

13. Our details
13.1 This website is owned and operated by Diviniti Publishing.

13.2 We are registered in England and Wales under registration number [number], and our registered office is at:

Diviniti Publishing Ltd,
Unit 1 Bourne Enterprise Centre,
Wrotham Road,
Borough Green,
Kent, TN15
8DG.

13.3 Our principal place of business is at the address above.

13.4 You can contact us:

(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on +44 (0)1732 882057; or
(d) by email on our contact page.