Privacy and Data Protection Policy – Astrolearn

1. Astrolearn is a trading name for a sole trader business of Philip Macartney Graves, a citizen of the United Kingdom of Great Britain and Northern Ireland. It was originally a registered business in Sweden between approximately March 2014 and September 2016; thereafter it became dormant and was discontinued in Sweden, but it is expected to be revived in the United Kingdom during the second half of 2018. All references to Astrolearn or to ‘we’ or ‘us’ in this policy refer to this business in either incarnation and / or its website at Astrolearn.com or personal representatives, as applicable to the context of the reference.

2. Astrolearn does not and will not in any circumstance sell or give your personal data to third parties, unless required to by a court order or judgement. The only circumstances under which Astrolearn may authorise third parties to process or store your data on our behalf are outlined below.

3. Unless expressly advised to the contrary, Astrolearn nonetheless reserves the right to mention you in the context of recommending your professional services or expertise to third parties if we believe that these may be of interest or value to them. Even in such a case, we will always request and ensure that we have obtained your express permission to pass on any personal contact details such as your email address before doing so.

4. We do not currently keep a mailing list for promotional purposes. Any emails sent to you will be in personalised response or reference to earlier communications you have made with us. If in the future we decide to introduce a mailing list and are considering including you, you will be asked first if you wish to opt in.

5. We may retain your personal communications voluntarily sent to us by email or through our contact form for an indefinite period of time unless you specifically request their deletion, in which case only communications providing documentary proof of purchases that we are required to keep for statutory tax accounting purposes will be retained.

6. All our email records relating to emails triggered by the filling in of the contact form are stored on hard drives within a password-protected desktop computer on our private premises. We do not use external email servers for any messages directly sent through the website. However, subsequent personal correspondence may be carried on from a gmail account, which is hosted based on cloud storage by Google.

7. Any comments you choose to post on pages or blog postings on the website Astrolearn.com will be retained there indefinitely unless either we choose to delete them for editorial or legal reasons or you delete them yourself.

8. Our website is hosted by a third-party hosting provider on shared servers at a data centre within the United States of America, using secure hosting. Data security is achieved through the full forced implementation of the https:// protocol throughout the site and by the limiting of administrative access to us.

9. The supply of digital book CDs, where purchased from us, is mediated through a data CD manufacturing and distribution company, Kunaki Inc., based in the United States. If you order CDs from us, we will share your chosen postage address but no further details with Kunaki in order that they can effect the direct shipping of the products you have ordered.

10. Payment for our products and services, if processed online, will require you to use an electronic payment method. Whether this is mediated by direct bank transfer or by a third-party payment processing service such as Transferwise or Paypal, you are responsible for your choices of which payment processing services to trust with your personal data. We suggest you read their privacy policies if you have any concerns. Any personal data we receive in connection with your payment will be kept strictly confidential.

11. We do not outsource client work or client liaison. Any employees or volunteers handling this will be based at our premises and bound by this privacy policy.

12. Individuals with whom we have had contact have the right to request a copy of the personal data that we hold about them. In such cases, they will be required first to prove their identity in order to protect the true individuals regarding whom such requests are made. The time taken to process such requests will be charged at a nominal hourly rate, pre-payable before the necessary searching and copying of information is undertaken.

13. Privacy by design is achieved by our conscientious attitude towards all processes involving the handling of the data of visitors to our website and customers.

14. This policy may be updated at any time. The date of the most recent revision will be shown below. Any changes will not be retroactive. We will honour the terms in force at the time of your dealings with us.

Last updated: May 23rd, 2018

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