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1.0 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION

  • User privacy and data protection are human rights
  • We have a duty of care to the people within our data
  • Data is a liability, it should only be collected and processed when absolutely necessary
  • We loathe spam as much as you do!
  • We will never sell, rent or otherwise distribute or make public your personal information

 

2.0 RELEVANT LEGISLATION

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.

 

3.0 PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT

This website collects and uses personal information for the following reasons:

3.1 Site visitation tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).

GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the analytics.js implementation of GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

In addition to Google Analytics, this website may collect* information (held in the public domain) attributed to the IP address of the computer or device that is being used to access it. The information is supplied to us from Whoisvisiting.com. Whoisvisiting.com is a service offered by Whoisdata Limited. The Whoisvisiting system does not use your IP address to identify you, the individual, in any way. No cookies are used by the Whoisvisiting system.

* The Whoisvisiting system will only lookup information when a static IP address is being used. Differences between a static and dynamic IP address.

More information about how Whoisvisiting uses IP addresses.

3.2 Our Shop

Placing an order: We will ask for information such as your name, address, phone number and email address. We may collect your IP address as part of our fraud screening process.

Taxes: Please be aware that international orders may be subject to additional import taxes and duties. These are the sole responsibility of the recipient. Any duties or taxes are the sole responsibility of the recipient. Any customs, import duties and associated fees are the responsibility of the recipient. International orders may be subject to local customs charges and as such are the responsibility of the recipient.

Creating an account: You must create an account with us, which stores your personal information (name, email address, address(es), phone number(s)) to allow you to view the video masterclasses. We do not store your payment details, but may store a token linking your account to card details stored by PayPal or Stripe, allowing recurring automated payments.

3.3 Contact forms and email links

Should you choose to contact us using the contact form on our Contact us page, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices and then deleted once the matter is resolved.

3.4 Email newsletter

If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.

Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

While your email address remains within the MailChimp database, you will receive periodic (approximately three times a year) newsletter-style emails from us.

4.0 HOW WE STORE YOUR PERSONAL INFORMATION

As detailed in section 3.2 above, if you purchase a subscription on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (WordPress). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.

Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.

5.0 ABOUT THIS WEBSITE’S SERVER

This website is hosted by SiteGround Hosting within a UK data centre located just outside London.

Some of the data centre’s more notable security features are as follows:

  • 3m rota-spike security fence and perimeter anti ram barriers
  • Blast proof anti-intruder shielded external windows and doors
  • Proximity access locks on all external and internal doors
  • Interlocked man-trap doors with biometric iris scanners to gain access into data floors
  • Server cabinets have locked doors (no open racks)
  • Perimeter and internal IP CCTV system monitored 24×7
  • 24×7 on-site security guards with static and mobile patrols
  • All on-site personnel are security vetted to BS7858 standard
  • Only authorised security cleared staff are allowed into the facility

All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

6.0 OUR THIRD PARTY DATA PROCESSORS

We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All 4 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.

 

7.0 DATA BREACHES

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

8.0 DATA CONTROLLER

The data controller of this website is: Simply Flute LTD.

Whose registered office is:
45 Keynsham road

London

SE9 6QE

 

9.0 DATA PROTECTION OFFICER

Mr. Pavel Mansurov
Director, Simply Flute LTD.
Email: pasha@simplyflute.com

10.0 CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

11.0 Fees; Renewal; Refund Policies.

Single-User Subscribers

11.1 Monthly

 

  1. Access to Standard Content
  2. Monthly subscription plan
  3. Automatically renews monthly until cancelled by Subscriber
    1. Automatically renews on the same date of each corresponding month or on final date of month if no corresponding date (January 31, 2011 subscription renews on February 28, 2011)
    2. Fees charged on renewal date
  4. Subscription fees are non-refundable; except that Subscriber may cancel renewed subscription in writing up to three (3) calendar days after renewal date and receive a full refund of the new subscription fees
  5. Discounts, rebates or other special offers only valid for initial term; subscriptions renew at the then-current full subscription rates
  6. simplyflute.com may increase subscription fees for a subsequent subscription period at any time and for any reason, provided, however, that simplyflute.com provides notice at least thirty (30) calendar days prior to the expiration of the subscription
  7. simplyflute.com may terminate the subscription and these Terms if it is unable to renew the subscription based on inaccurate or outdated credit card information
  8. Right of Access to the Website granted under these Terms is effective only upon payment of the subscription fees
  9. Subscriber is responsible for maintaining their account. Simply Flute is not responsible or obliged to refund duplicate account creations.

11.2 Annual

  1. Access to Video Content
  2. Annual subscription plan
  3. Automatically renews yearly until cancelled by Subscriber
    1. Automatically renews on the same date of each corresponding year or on final date of month if no corresponding date (e.g., February 29th)
    2. Fees charged on renewal date
    3. Subscriptions purchased after May 1, 2013 shall automatically renew as set forth herein
  4. Subscription fees are non-refundable; except that Subscriber may cancel renewed subscription in writing up to three (3) calendar days after renewal date and receive a full refund of the new subscription fees
  5. Discounts, rebates or other special offers only valid for initial term; subscriptions renew at the then-current full subscription rates
  6. simplyflute.com may increase subscription fees for a subsequent subscription period at any time and for any reason, provided, however, that simplyflute.com provides notice at least thirty (30) calendar days prior to the expiration of the subscription
  7. simplyflute.com may terminate the subscription and these Terms if unable to renew the subscription based on inaccurate or outdated credit card information
  8. Right of Access to the Website granted under these Terms is effective only upon payment of the subscription fees.
  9. Subscriber is responsible for maintaining their account. Simply Flute is not responsible or obliged to refund duplicate account creations.