Privacy Policy

This policy covers the following matters (amongst others): the collection of personal information; the use of that personal information; the legal bases for the processing of that information; disclosures of that personal information to third parties; international transfers of personal information; and the use of cookies on the website.

In any event, there are many aspects to data protection compliance. Publishing a privacy policy or statement containing the relevant information is only one aspect - albeit an important aspect - of compliance.

Section 1: Introduction

Section 1.1

"Personal data" is defined in Article 4(1) of the GDPR:
"(1) 'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

Section 2: Cookies
The inclusion of this statement in your privacy policy will not in itself satisfy the requirements of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as regards consent to the use of cookies. Guidance concerning methods of obtaining such consent is included on the Information Commissioner's website (http://www.ico.gov.uk).


Section 3: How we use your personal data

Article 13(1) of the GDPR provides that:
"(1) Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information: ... (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing; (d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party".
Article 6(1)(f) of the GDPR provides that:
"(1) Processing shall be lawful only if and to the extent that at least one of the following applies: ... (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child."

Section 3.1
Article 14 of the GDPR, which applies where personal information is not obtained from the data subject, provides that information about "the categories of personal data concerned" must be supplied to data subjects.
Article 13 of the GDPR, which applies where personal information is obtained from the data subject, does not include an equivalent provision.
Nonetheless, we have included references to general categories of data in this document, because this facilitates the identification of particular purposes of processing and the legal bases of processing - information which does need to be provided under Article 13.

Section 4: Providing your personal data to others

Article 13(1)(e) of the GDPR requires that where personal data are collected from the data subject, the data controller must provide the data subject with information about "the recipients or categories of recipients of the personal data".
Equivalent rules for data collected from someone other than the data subject are in Article 14(1)(e).

Section 4.1

Section 5: International transfers of your personal data

Article 13(1)(f) of the GDPR requires that data controllers disclose to data subjects "where applicable, the fact that the controller intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 [transfers subject to appropriate safeguards] or 47 [binding corporate rules], or the second subparagraph of Article 49(1) [limited transfers for compelling legitimate interests], reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available".

Section 5.1

Will users have the opportunity to publish personal information on the website?

Section 5.2

What details do you hold?

Our website contains no personal data like email, phone numbers or addresses. However to provide our data services we do hold the following info.

- Social media usernames/ids
- IP Addresses
- Email (Optional)
- A Collection of user ids that follow you
- Dates corresponding the the above activity's
- Lists of error codes generated

Section 6: Retaining and deleting personal data

Article 5(1)(e) of the GDPR sets out the storage limitation, one of the fundamental rules of the regime:
"Personal data shall be: ... kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject ... ".

Section 7: Amendments

Section 8: Your rights

Section 8.1

Article 13(2) of the GDPR provides that, where personal data is collected from a data subject, certain information about data subject rights must be provided:
"In addition to the information referred to in paragraph 1, the controller shall, at the time when personal data are obtained, provide the data subject with the following further information necessary to ensure fair and transparent processing: ... (b) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability; (c) where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal; ...".
Similar provisions are set out in Article 14 in relation to personal data which is not collected from the relevant data subject.

Section 8.3
The right to access is set out in Article 15 of the GDPR.

Section 8.4
The right to rectification is set out in Article 16 of the GDPR.

Section 8.5
The right to erasure (or right to be forgotten) is set out in Article 17 of the GDPR, and must be notified to data subjects under Articles 13(2)(b), 14(2)(c) and 15(1)(e) of the GDPR.
Consider modifying the highlighted circumstances and exclusions, depending upon what will be most relevant to your processing.

Section 8.6
Article 18(1) of the GDPR states:
"The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; (d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

Section 8.7
The right to object to processing is detailed in Article 21 of the GDPR, and must be notified to data subjects under Articles 21(4), 13(2)(b) and 14(2)(c).

Section 8.8
Optional element.
Article 21(3) of the GDPR states:
"Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes."

Section 8.9
Optional element.
This right is set out in Article 21(6) of the GDPR. 

Section 8.10
The right to data portability is set out in full in Article 20 of the GDPR, and must be notified to data subjects under Articles 13(2)(b) and 14(2)(c).

Section 8.11
The right to lodge a complaint with a supervisory authority is set out in Article 77 of the GDPR, and must be notified to data subjects under Articles 13(2)(d), 14(2)(e) and 15(1)(f). 

Section 8.12
Article 7(3) of the GDPR sets out the right of withdrawal. The right must be notified to data subjects under Articles 13(2)(c) and 14(2)(d). See also Article 17(1)(b).

Section 9: About cookies
The full list of cookies processing and information is found via the cookies policy page.

Section 10: Cookies that we use
Site management only used for monitoring your use within our website.

Section 11: Cookies used by our service providers

The following service providers also use cookies on this site. Twitter, Soundcloud, Google Adsense and Google Analyitics

Further information on these companies privacy policies can be found below.

Amazon

https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=201909010

Google Adsense

https://policies.google.com/privacy?hl=en&gl=US

Google Analytics

https://support.google.com/analytics/answer/6004245?hl=en

Twitter

https://twitter.com/en/privacy

SoundCloud

https://soundcloud.com/pages/privacy

Section 11.3
Google AdSense advertisements will be published on this website.
This provision should be included if you publish Google AdSense interest-based advertisements on your website. Additional disclosures will be required if you have not opted out of third-party ad serving.
If the website sets any other cookies to users' machines that track behaviour, information about those cookies will also need to be disclosed.

Section 12: Managing cookies
Full information on how to manage cookies is found on the cookies page.

Section 12.3
Blocking of cookies will not affect the use of our core service.

Section 13: Data protection officer

Section 13.1

Some data controllers and data processors will have an obligation to appoint a data protection officer (DPO). The basic obligation is set out in Article 37(1) of the GDPR:
"(1) The controller and the processor shall designate a data protection officer in any case where: (a) the processing is carried out by a public authority or body, except for courts acting in their judicial capacity; (b) the core activities of the controller or the processor consist of processing operations which, by virtue of their nature, their scope and/or their purposes, require regular and systematic monitoring of data subjects on a large scale; or (c) the core activities of the controller or the processor consist of processing on a large scale of special categories of data pursuant to Article 9 and personal data relating to criminal convictions and offences referred to in Article 10."

Article 13(1)(b) of the GDPR provides that:
"(1) Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information ... (b) the contact details of the data protection officer, where applicable".
See also Article 14(1)(b).

Trademarks, Logos and Copyright

Unfollowspy is not linked to Twitter™ or SoundCloud™ and solely uses there individual API interfaces. All trademarks acknowledged and property of their respective owners.

Last Updated: 22.05.2018