Privacy Policy | Kgreenbooks

This is the privacy policy for kgreenbooks.com, the author website for K. Green, trading as Hidden Dell Press.

We value your privacy and, in truth, would prefer to collect as little of your data as possible.

Unfortunately, the modern internet makes this extremely difficult and some of the legislation that protects your data requires us to collect certain data that we would not collect otherwise. This Privacy Policy sets out why we collect your data, what data we collect, how it is handled, and your rights over it.

A. Overview:

Except in anonymised aggregate form (e.g. site traffic statistics, etc.) we ourselves only make use of your data for three purposes:

to make this website available to you;
to manage messages via the “Contact” form and/or email;
to operate our two newsletters (“My Monthly Newsletter” and “Book Release Announcements”).

In order to do these things, we make use of third-party service providers. These third-party service providers also collect data from you, nominally and legally on our behalf and at our direction. Except in a few cases as outlined below, this direction is largely implicit as a result of our use of their services and our acceptance of their terms.

These third party service providers each have a Data Processing Agreement with us, in which they commit to us that they will only process your data according to the terms of those agreements and to a number of jurisdiction-specific regulations, including the GDPR.

Under the GDPR, you have the right to access, correct or erase your data, to restrict or object to certain forms of processing, or to request the transfer of your data to another organisation or directly to yourself. These rights are subject to certain conditions.

If you subscribe to either of our newsletters, you have the right to unsubscribe at any time.

B. Our own use of your data:

As mentioned above, except in anonymised aggregate form (e.g. site traffic statistics, etc.) we ourselves only make use of your data for three purposes:

to make this website available to you;
to manage messages via the “Contact” form and/or email;
to operate our two newsletters (“My Monthly Newsletter” and “Book Release Announcements”).

We will never sell your data.

We do share your data, including your messages, with our third-party service providers, subject to their Data Processing Agreements with us. We may also share your data with law enforcement when necessary, or with any other recipient if we have a legal or regulatory obligation to do so. We may also share your data, at your direction, if you exercise your right to data portability.

We will only use any message you send us in accordance with any purpose stated or implied by its contents, e.g. to act on your request to exercise one of your rights under data protection legislation. In most cases, messages will simply be read by myself, Kelly.

Please do not share private or sensitive information in any message you send to us.

If your message relates to a specific purpose or request then we will retain your message only as long as necessary. Otherwise (and especially if your message says something nice) we will retain your message until you ask us to delete it.

We operate two different newsletters, “My Monthly Newsletter” and “Book Release Announcements”, differing in when and why they are sent:

“Book Release Announcements” are sent only to announce the release of a new book and only once per release;
“My Monthly Newsletter” is sent monthly and contains a variety of useful or interesting content relating to myself, my books, the world of writing, and more.

You may unsubscribe at any time using the “unsubscribe” link included in every newsletter.

For purposes 1 & 2 our lawful basis for processing your personal data is that we have a legitimate interest in making the website available to you and in making it possible for you to contact us. For purpose 3 our lawful basis for processing your personal data is that we have obtained your consent to send marketing communications to you. You have the right to withdraw this consent at any time.

C. Third-Party Service Providers:

This website is built upon the Wix.com platform;
our newsletter service is provided by MailerLite;
our email inbox is hosted by Google Workspace.

We may change our third-party service providers in future. We will update this policy if we do. Your data will only be transferred to a new third-party service provider if it commits to and provides an equivalent or better level of data protection and is compliant with all relevant regulations, including the GDPR. If this is not possible then your data will not be transferred, which may result in some loss of service (e.g. being unsubscribed from our newsletters).

Our use of the Wix platform:

This website is built upon the Wix.com web hosting platform. Wix has committed through its Data Processing Agreement to only use your data for a limited set of purposes that support their provision of that service, that protect themselves from certain risks, or that enable them to comply with their legal or regulatory obligations.

This Data Processing Agreement is an agreement between Wix and ourselves but it is also a public document that you can find at “wix.com/about/privacy-dpa-users”. It sets out five permitted purposes for the processing your data:

To provide us with their service;
To process your data at our direction (see below);
To fulfil their contractual obligations to us, enforce our obligations to them, and defend Wix’s rights;
To prevent, investigate or mitigate errors, attacks or misuse;
To comply with their legal and regulatory obligations.

In the course of processing your data, Wix may transfer your data to a sub-processor but only for the purpose of providing the service and only as much of your data as is necessary for that purpose.

Wix may also transfer your data across international borders but only in accordance with jurisdiction specific safeguards and Data Protection Laws, as outlined in the section titled “F. International Transfers” of their Data Processing Agreement with us.

How we direct Wix to process your data:

Beyond the implicit direction resulting from our use of their service, we have only further directed Wix to collect your data for the purpose of operating the “Contact” section of the site, which enables you to leave us a message. Any information you submit through this form will be saved into a database hosted by Wix and visible to us. We will also receive a copy of the message to our email inbox, which is currently hosted by Google Workspace.

Please do not share private or sensitive information in any message you send to us.

Our use of MailerLite:

Our newsletter service is provided by MailerLite. In the provision of this service, MailerLite processes some data on our behalf, subject to its Data Processing Agreement with us, as well as collecting some data on its own behalf, subject to its own Privacy Policy.

With respect to data processed on our behalf, MailerLite has committed through its Data Processing Agreement with us that it will process your data only for the purpose of the provision of its services. Although this Data Processing Agreement is an agreement between MailerLite and ourselves, it is also a public document that you can find at “mailerlite.com/legal/data-processing-agreement”.

With respect to data collected on its own behalf, you can review MailerLite’s Privacy Policy at “www.mailerlite.com/privacy-policy”.

In order to send you the newsletter we require your email address, your consent to receive emails from us, and a record proving that we have this consent.

We obtain your email address and consent when you complete the newsletter subscription form and confirm this consent via a confirmation email. In order to create a record of proof that we have this consent, the form will also collect your IP address and location, as well as the date, time and source of subscription.

We appreciate that interest in a given newsletter may decay over time and so in order to avoid sending unwanted spam we make use of the “opens tracking” system provided by MailerLite. This system tracks whether or not a recipient of the newsletter has opened it. This allows us to identify subscribers who no longer seem interested in receiving the newsletter so that we can remove them from the subscriber list. This helps us with our obligation to maintain your ongoing consent.

In the course of processing your data, MailerLite may transfer your data to a sub-processor but only for the purposes of providing and maintaining the service and only as much of your data as is necessary for that purpose.

MailerLite may also transfer your data across international borders but only in accordance with jurisdiction specific safeguards and Data Protection Laws, as outlined in the section titled “13. International Transfers” of their Data Processing Agreement with us.

How we direct MailerLite to process your data:

Beyond the implicit direction resulting from our use of their service, we have further directed MailerLite to implement “double opt-in” subscription, “interest groups” selection, and “opens tracking”.

“double opt-in" subscription involves the sending of a confirmation email to confirm your consent and to verify that you are the owner of the email address used to sign up. This results in the collection of a small amount of additional data necessary to record subscriber status and consent.
“interest groups” selection allows you to choose either or both of our newsletters and collects a small amount of additional information to record this selection.
“opens tracking” embeds a link to a unique invisible image within our newsletter. This results in the creation of a very small record each time that this image is “displayed”, specifying which recipient has opened which newsletter and when.

Our use of Google Workspace:

Our email inbox is hosted by Google Workspace. All emails are encrypted at rest and in transit between Google’s facilities and Google are not generally able to access or use the contents.

However, depending on the contents of these emails, they may still qualify as your personal data. To whatever extent Google might be able to access your personal data, their Data Processing Agreement with us commits them to only processing your data for the purposes of providing their Services and Technical Support Services (if applicable).

Although this Data Processing Agreement is an agreement between Google and ourselves, it is also a public document that you can find at “cloud.google.com/terms/data-processing-addendum”.

Google may transfer your data to a sub-processor, provided that all of Google’s data protection obligations under their agreement with us are imposed upon the sub-processor.

Google may also transfer your data across international borders but only in accordance with jurisdiction specific safeguards and Data Protection Laws, as outlined in the section titled “4. Data Transfers” of their Data Processing Agreement with us.

D. Cookies We Use:

This site only sets essential cookies that are necessary for the correct functioning of the site as hosted upon the Wix.com platform. We do not offer an opt-out option to reject non-essential cookies, as we currently do not set any.

E. Your Rights:

Right to access – You have the right to request copies of any of your personal data that we or our third-party providers hold. We may charge a reasonable fee for this service.
Right to rectification – You have the right to request that we correct or complete any information that you believe to be inaccurate or incomplete.
Right to erasure – You have the right to request that we erase your personal data, subject to certain conditions. In particular, we may be required by law or regulation to retain your personal data for certain purposes or to retain certain types of data for a certain period of time.
Right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain limited conditions, e.g. while awaiting a correction under the right to rectification.
Right to object to processing – You have the right to object to the processing of your personal data if you object to purpose for which it is being processed: if this purpose is for marketing (e.g. to serve you our newsletter) then we must comply.
Right to data portability – You have the right to request that we transfer your data to another Data Controller or directly to yourself, e.g. as normally invoked as part of a switching service.

You can contact us via the Contact form on our website or at kelly@kgreenbooks.com if you wish to exercise any of these rights.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) in the UK or the European Data Protection Supervisor (EDPS) in the EU:

UK: ico.org.uk/make-a-complaint/

EU: edps.europa.eu/data-protection/our-role-supervisor/complaints_en