I am committed to safeguarding the privacy of everyone who uses this website. 

This policy sets out how I use your personal data as and when any data is given to me by you as a user of this site.

This policy reflects my duties under the General Data Protection Regulation 2016 (GDPR), the Data Protection Act (1998), and all applicable Privacy and Electronic Communication Regulations. This policy describes how I use your personal data as and when such data is given to me fairly, how I keep that data secure, how I make sure that data is accurate, and how I uphold your rights to your data as a data subject.

Please read the following policy to understand how your personal information will be treated. Please note that this policy may need to be updated and that as such its content may change from time to time. You are strongly encouraged to check this page from time to time to see the most recent versions. This policy was most recently updated in September, 2020.

I, Gary Bloomer, am the data controller for the information you provide. My mailing address is: 105 Christina Landing Drive, Suite 807, Wilmington, DE 19801, United States of America. I can be contacted via email at gary @ garybloomer [dot] com

How I use your data

If you have given me your name or email address via an opt-in form, or if you have bought something from me that requires your mailing address or telephone number, I may routinely use your personal data for the following purposes:

1. Registering you as a subscriber to this website.
2. Contacting you about your content updates, about membership if you are a premium member, and about offers that may interest you as a subscriber.
3. Representing you effectively.

If you have not completed a subscription form and have not given me your name, or email address, or any other personal details about you, I do not possess any of your personal data.

The lawful basis for this processing, where it applies, is in me pursuing my legitimate interests as a content publisher. I may also use legitimate interest as my lawful basis for the following data processing:

•  Holding your data on my subscriber and membership database.
•  Processing your subscription payments as and when they become due.
•  Confirming your identity when you contact me as a subscriber.
•  Sending you communications that I believe may benefit you as a small business owner.
•  Sending you updates and details about newly added content.
•  Administering membership benefits and determining your eligibility for these benefits.
•  Statistical analysis of your membership or subscription to this website.

Accessing your personal data 

Some of your personal data will be available to me for the purposes of carrying out specific activities related to updating you on details about this website.

The type of personal data will be relevant to the purpose for which the data is used. No data is shared with third parties.

Data security

I take great efforts to safeguard the confidentiality of your personally identifiable information. These efforts include SSL (secure socket layer) encryption. While I make every effort to protect against any and all loss, misuse, and alteration of information under my control, users of this site should understand that all data transmission over the Internet is inherently insecure and that as such, I cannot nor will I guarantee the security of data sent to this website over the Internet.

If you have elected to use any of the gated or premium information on this site that is password-protected, other than any lost password access that may be granted to you or agents acting on your behalf, you are responsible for maintaining the secrecy of your password and user name (log-in details). I take data security extremely seriously and any data protection breaches are handled in line with the following data breach protocol:

The European Union (EU) General Data Protection Regulation (GDPR) 2016 defines a personal data breach as a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. 

Because I take data protection seriously, I work hard to ensure that all processing of data is compliant with the GDPR and all relevant data protection legislation. 

Upon the discovery of any data breach, I will deal with the issue in line with Recital 87 of the GDPR; when a security incident takes place I will quickly establish whether a personal data breach has occurred and if so, I undertake to promptly take steps to address said breach. 

All agents acting on my behalf are aware that any data breach should be reported to the data protection officer as soon as they become aware of it. 

My data protection department can be contacted by email at 

gary @ garybloomer [dot] com

When emailing the data protection department I will do my best to respond to your questions and concerns within 7 working days. However, I will ensure that anything of an urgent nature such as data breaches is responded to within 48 hours. 

When reporting a breach, please provide the following information in order to establish the likelihood and severity of the resulting risk to your rights and freedoms: 

•  the date the incident occurred
•  the date the incident was identified
•  a description of the breach
•  estimated number of people affected
•  description of personal data involved
•  summary of action taken

In assessing the risk to rights and freedoms, I will focus on the potential negative consequences for individuals; and assess on a case-by-case basis. If it’s likely that there will be a risk to an individual, I will notify the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach. 

I will inform those concerned directly without undue delay, similarly, I will provide details on the steps taken to contain any such breach, along with corrective actions to prevent any future or similar occurrence. 

I record all data breaches, whether such breaches are reported to the ICO or not, on an internal register. I offer advice and guidance on how individuals can prevent recurrence and also use the information from breach reports to inform improve services.

Sharing your personal data with third parties

By third parties, I mean organizations, websites, and content providers that are not part of this website.

I may need to share your information with third parties such as mailing houses that may be retained to print and send any mailed and printed communications to you. In this instance, this information will include your name and your mailing address, details which are required in order to ship such material to your physical location. 

In doing so you can be assured that I will only share the minimum amount of data required for the purpose of the data processing. This means if I need to send you something in the mail that I would not also share your email address with the mailing house, because that piece of personal data is not needed to complete the process. 

I also ensure that processes are in place so that data is always transferred to third parties securely. The third parties I share data with include:

•  any mailing house that prints and sends my postal communications.

Mailing details and street address data can only be share if you give it to me. Any data given by you for subscription purposes is not retained on or by this website and any and all such data is secured by those entities connected with that data, such as email auto-response services such as MailChimp. 

I may occasionally need to share personal data with organizations working to detect or prevent fraud and crime. These agencies include Federal, city, state, and county law enforcement departments. You will be notified if law enforcement agencies request personal data.

Market research

From time to time, I may use your name and email to send you offers for goods and services I believe may be of value or use to you as a small business owner. All such emails will include a clearly marked unsubscribe option for your use should you choose not to receive future email.

None of your personal data (including your name, email address, telephone number, and mailing address) will ever be made available to any third party market research companies without your express consent. 

Transfers overseas and safeguards

I do not routinely transfer your data outside of the United States. Where they are necessary, I ensure appropriate data protection measures are in place.

Retention of data

Retention refers to the length of time I keep your data. Your data will be retained until you unsubscribe from any and all lists. In the event that you enter into abusive communication, including fraud, theft, intentional misrepresentation, slander, and liable, your data may be removed from my records prior to any unsubscribe.

Your rights as a data subject:

You have rights as a data subject. These rights are:

1.  The right to be informed – this means I must inform you how I am going to use your personal data. I do this through this privacy policy and by informing you how your data will be used each time I collect it.

2.  The right of access – you have the right to access your personal data (e.g. data that is about you) that I hold. This is called a subject access request. 
I will respond to your request within one month of receipt of your request. To request access to your data, please email gary @ garybloomer [dot] com. In your request, please clearly outline what elements of your personal data you are seeking.

3.  The right to rectification – if you think the data I hold on you is incorrect, please tell me so we can correct matters. You can do this by emailing: gary @ garybloomer [dot] com

4.  The right to erasure – you have the right to request that I delete your data. If you opt to have your data removed from my records I will do so, provided that I do not have a compelling reason for keeping it. To request that your data be erased, please email gary @ garybloomer [dot] com

5.  The right to restrict processing – you can change your communication preferences (therefore restricting how I communicate with you) by emailing me at

gary @ garybloomer [dot] com

6.The right to data portability – you can obtain and reuse your personal data for your own purposes across different services, for example different websites. To request this, please email dataprotection@garybloomer.com.

7.  The right to object – you have the right to object to direct marketing from me or from third parties I may have shared your data with for direct marketing purposes. You can opt-out of direct marketing any time by emailing:

gary @ garybloomer [dot] com

Your right to complain

I am committed to upholding your rights as a data subject. 

If you think I have not done so, please contact me gary @ garybloomer [dot] com

and I will do my best to ensure your concerns are addressed and I will see to it that your complaint is reviewed and corrected to the best of my ability.

If, after that, you are still not happy with the outcome and if you believe your data rights have not been upheld, you may complain to the Information Commissioner’s Office (ICO). The ICO is the data protection regulator and their website is: www.ico.org.uk.

In the European Union, if you are an EU citizen you may complain to the European Commission by visiting: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/redress/what-should-i-do-if-i-think-my-personal-data-protection-rights-havent-been-respected_en

Consent

There are some types of data processing that I only do if you have given me your consent. These are:

•  Sending direct marketing messages by email.
•  Sharing your data with third-party providers of membership benefits.

You are in control of what consent you give me. 

You can withdraw your consent at any time by emailing me at gary @ garybloomer [dot] com, OR by unsubscribing from my emails by using the unsubscribe link at the bottom of every email you receive from me. If you unsubscribe I will delete your email address from my records and you will not hear from me again. 

Statutory data requirements

I have a statutory requirement to keep an accurate register of subscribers.

Data collected on this website

Personal data collected by this website will only be used for the purposes (or closely related purposes) for which it was collected.

I may use your personal information to:

•  Administer the website.
•  Improve your browsing experience by personalizing the website.
•  Enable your use of the services available on the website.
•  Deal with inquiries and complaints made by you relating to the website.

Email

All the email I send to my subscribers is tracked. This means my email service gives me certain pieces of information about the delivery and receipt of the email messages I send. This information may include the date and time the email was sent, along with when the message was opened and which links within the email were clicked on, if any. This information helps me ensure that you only receive emails from me that are of interest to you. If you consistently receive but do not open emails from me, I reserve the right to remove your details from my email list and I reserve the right to delete your details from my records. You can unsubscribe from emails at anytime by clicking the ‘unsubscribe’ button at the bottom of every email I send.

Cookies

When you visit this website, data may be stored on a 'cookie', which is a tiny element of data that this site sends to your browser, which is then stored on your computer’s hard drive. This small amount of information does NOT access any personal data stored by you on your computer. Instead, cookies are designed to improve your user experience of this website. 

I ask when you first access this site if you are happy for cookies to be used. If you choose not to use cookies, it may be difficult to use some parts of this website.

Social media buttons

On multiple pages of my website you will come across social media ‘share’ buttons that connect your use of related content on this website to social media sites such as Twitter, Instagram, Facebook, Pinterest, YouTube, and LinkedIn. 

If you are a registered user of and are actively logged in to any connected social media platform and you share content from this website to your account on any of the social media platforms listed above, the specific site you share my content to will register that action and may use that information for tracking purposes which may include advertising-related content that the related social media site may serve to you as a user of that specific platform.

Please note that other than any advertising that I or this site may place on any of the social media platforms noted above, neither I, nor this website have any other direct advertiser-related connection to the social media site or sites you use or to any related advertisements you may be served as a result of your use of such sites. 

You are strongly advised to consult the respective terms of service and user policies of each social media site you use to see how each of those sites uses or manages your information and to find out how you can to opt-out of, or delete, such information from those sites.

Facebook advertising

From time to time I may run advertising on Facebook and other social media platforms to promote my content and offers. I do not currently and have no future plans to collect any personal data from the personal profiles of any users of Facebook or any other social media platform. Likewise, I do not use your data to target my advertising on social media platforms, nor do I or will I ever provide or sell the data of users of this website to third parties for the purposes of social media or email marketing. To no longer receive social media ads, please follow the relevant on-screen prompts to remove yourself from advertising on the social media platform involved. 

External web services

On this website, I may use external web services to display content within specific web pages on this site. 

For example, to display certain elements of video content I may link to YouTube, Vimeo, Wistia, or related websites that store and stream video content. I may also host images from sites such as Unsplash, Freepik, and Flickr (this is not a complete list of the image or video services I currently use or may use in the future when embedding content but these are the most common sites).

As with the social media buttons, these sites may use information about embedded content. If you are not logged-in to these external services, they will not know who you and as such will not track any personal information about you and who you are, but these sites may gather and use anonymous usage information about your activity including the number of views, plays, and individual content loads of the related images or video from your ISP (Internet Service Provider) which may include your geographic location along with your browser type.

If you have ANY concerns about your privacy on this website, PLEASE contact me via email at gary @ garybloomer [dot] com and I will do everything I possibly can to address your questions and concerns.

This page was last updated on December 29, 2020.