Privacy and Cookies



Updated on 25 May 2018 
 
Soberistas Ltd is very aware of the importance of our worldwide community maintaining privacy whilst sharing in what our community has to offer.  It is really important in order to help each other that our community feels able to share our stories and comments, and to blog freely.  However, we very strongly encourage our members to use a username specific to this community and to ensure that others reading their stories cannot identify them.  The issue of privacy, not only for the members but for their family is very important to us all, as the Soberistas community should be free to benefit from what we offer without being concerned about the effect on family and friends.  
 
This Privacy Policy is designed not only to comply with information rights that our community have under the General Data Protection Regulations (GDPR) but it is also designed to remind our members of their own responsibilities and accountability in terms of privacy. Throughout this Privacy Policy we refer to Soberistas as “we” or “us” and to our members as “you”.  
 
Privacy or data protection law may change a little following Brexit.  We may therefore update this Privacy Notice from time to time and we recommend that you refresh your reading of it occasionally.  
 
We have tried to reduce the “jargon” in this notice and so we have included a “jargon buster” at the end.  Clicking on some of the words or phrases will take you through to the jargon buster.  
 
Our website is for adults only.  If you are under 18 there is other support available to you from your GP, health clinic or by visiting the useful contacts section.
 
1. Who We Are
 
We are Soberistas Ltd of 88 Murray Road, Sheffield S11 7GG. 
 
Our contact details are enquiries@soberistas.com
 
If you have a privacy concern or complaint you should contact Sean Kilbane at enquiries@soberistas.com. 
 
You can also contact the privacy regulator, the Information Commissioner’s Office (ICO) by telephoning 0303 1231113 or via their website ICO.org.uk/concerns.  
This Privacy Policy sets out the basis on which any personal data we collect from you or that you provide to us, will be processed when you use the Website. We are committed to protecting and respecting your privacy.
Please see our website terms of use for important information on our website generally.
2. Personal Data 
 
-      Personal Data (personal information) means any information about an individual from which that individual can be identified.  
-      We collect the following personal data from you or about you: - 
-      Your username
-      Your email address
-      Your IP address
-      Your location (optional)
 
However, very importantly, every piece of information which you provide via our website which can be read by other members can be personal data.  You are completely in control of what you choose to share, which is why we emphasise the importance of your privacy and your choice as to personal data shared.  
 
3.  Why we collect some personal data (purposes)
 
We use the contact details we obtain to provide you with the services we offer in particular our newsletter or if we receive an enquiry from you in order to respond.  
 
We have to have a lawful basis to use your Personal Data in this way and also to contact you by email.  More information about the lawful basis for processing is at the jargon buster at the end of this Privacy Notice.  
 
Where you contract with us for services the lawful basis we rely upon is the performance of the contract.
 
We also rely upon consent.  By signing up to our community you are receiving the services that the community offers you and are consenting to our providing you with our newsletters and our contacting you by email.  We also process your data where it is necessary for the purposes of our legitimate interest, for example to analyse whether we should make changes to the services we provide.  However, we will not process your data for the purposes of our legitimate interest where those interests are overridden by your interests or fundamental rights and freedoms.
We use information held about you in the following ways:
·      to help you give up alcohol, or reduce or control your alcohol consumption. We may contact you by email and provide newsletters and other information to you about alcohol consumption and health related issues but only if you consent to this by ticking the relevant box;
·      to ensure that content from our Website is presented in the most effective manner to you;
·      to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
·      to carry out our obligations arising from any contracts entered in to between you and us;
·      to allow you to access to participate in live chat, Twitter, Facebook, feedback, reviews and any other interactive features available on our Website from time to time; and
·      to notify you about changes to our Website.
·      We may also use your data or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email, post or telephone but only if you have consented to this.
·      If you want us to use your data in this way or to pass your details on to third parties for marketing purposes, please tick the relevant boxes when you register on our Website.
·      We do not disclose information about identifiable individuals to our advertisers, but we reserve the right to provide them with aggregate anonymised information about our users.
·      We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
·      To respond to any queries which you have made to the Soberistas administrative team regarding your usage of the Soberistas website, your membership or any other query to which we need to reply. 
·      For any issues regarding your Soberistas membership. 
 
4. Is your data shared?
 
We never sell your data.  
 
In order to provide the services we offer we have to use third party providers called “Data Processors” – see jargon buster.  We provide you with more details of these parties below.  Apart from the companies who supply services to us, we do not share your data with any third parties.  We use the following Data Processors and we have contractual arrangements with them to ensure that they comply with data protection law and keep your data safe. Those contractual arrangements also ensure that they cannot process your data in any way without our authority.  
 
We use Amazon Web Services, a fully GDPR compliant organisation. Further details of Amazon Web Services and how the organisation is GDPR compliant can be found here: https://aws.amazon.com/privacy/
 
Further information on the EU-US Privacy Shield can be accessed here: https://ico.org.uk/concerns/eu-us-privacy-shield/
 
The Soberistas website is managed by the UK based software company known as Finer Vision - Registered Company Number 07042837.Finer Vision is fully GDPR compliant and its Privacy Policy can be found here: https://finervision.com/PrivacyPolicy.pdf
5. Is my data transferred outside the UK?
 
The chat server we use is located in the UK and GDPR applies. Amazon Web Services store images on AWS S3, a content delivery network, which is distributed globally.  The server is located in the United States (Oregon) and information may travel through servers outside the EU.  
6.  Cookies and Weblinks
Our Website uses cookies to distinguish you from other users. This helps us to provide you with a better browsing experience and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy below.
Our members may choose to place links to websites on their blogs.  We are not responsible for these.  Please take care when deciding to follow a link.
We also host advertising links from time to time.  We advise that you read the Privacy Policy of any third party website you visit.
7.  Disclosure of your information
We may disclose your personal information to any member of our organisation, group and any other organisation working with us (where required) for the purposes of operating Soberistas.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
If Soberistas Ltd or substantially all of its assets are acquired by a third party in which case personal data held by it about its customers will be one of the transferred assets; or
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our Website Terms of Use or to protect the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
8. How long do we keep your personal data for?
 
We keep your personal data for as long as you are a member of the Soberistas website and newsletter community.  You can end your membership or ask for your data to be deleted at any time and your data will not be retained once deleted.  You can unsubscribe from the newsletter any time by clicking on the relevant link on the newsletter. 
 
9. Data security and data breaches
 
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  We limit access to your personal data to those employees, agents, contractors and any third parties who have a business need to know and any such will only process your personal data on our instructions and are subject to a duty of confidentiality.  However the sending of information via the internet can never be seen as totally secure and you should always take steps to consider your own safety and security.
 
We have put in place procedures to deal with any suspected personal data breach and will notify you and the data privacy regulator (Information Commissioner’s Office) of a breach where we are legally required to do so.  
 
10. Your legal rights
 
You have the right to:-
 
-      Request access to your personal data;
-      Request correction of your personal data;
-      Request erasure of your personal data in certain circumstances;
-      Object to processing of your personal data;
-      Request restriction of processing your personal data;
-      Right to withdraw consent.
 
Request access to your personal data (commonly known as ‘data subject access request’).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it and to give you an opportunity to request correct, if appropriate.
 
Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
 
Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no lawful reason for us continuing to process it or where, despite a lawful reason there is no good reason for us continuing to process it in the light of your request.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we accept that we have processed your information unlawfully.  However we may not always be able to comply with your request for erasure for specific legal reasons which we will notify to you, if applicable, at the time of your request.
 
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal data for direct marketing purposes.  We operate on the basis of consent for direct marketing and we try to make it as easy as possible to withdraw consent at any stage.  Where you object to processing of your personal data, in some cases we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
 
Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios:-
 
(a)  If you want us to establish the data’s accuracy;
(b)  Where you believe our use of the data is unlawful but you do not want us to erase it;
(c)  Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d)  You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
 
Withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out because you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
 
Jargon Buster
 
“Data Controller”                   we are a Data Controller.  This means that we are responsible for deciding how we hold and use personal information about you.  
 
“Data Processor”                    this means an organisation which processes Personal Data on our behalf.  
 
“Processing”                            this means any operation or set of operations performed on personal data or sets of personal data and includes collecting it, structuring it, storing or retrieving or consulting it, using it in any way, disposing or sharing it, restricting it, erasing it or destroying it.  
 
“Personal Data breach”        means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.  
 
“Lawful processing”               means one of six reasons under which Personal Data may be lawfully processed.  These include: - 
 
·   The individual has given consent to the processing of his/her Personal Data for that specific purpose, in other words, the individual must be fully informed and clear about exactly what they are agreeing to.  
·   Necessary for the performance of a contract between the individual and another. 
·   Necessary for compliance with a legal obligation, which applies to the Data Controller. 
·   Necessary for the purposes of the legitimate interests pursued by the Data Controller (or by a third party). However, there are legitimate interest tests, which apply and those tests include what interests are legitimate. Also, a legitimate interest can be overridden by the interests or fundamental rights and freedoms of the individual, which require protection.  
Cookies
We use cookies and similar tools across our Website to improve performance and enhance your user experience. This policy explains how we do that.
1.         What are cookies?
Cookies are small text files which a website may put on your computer or mobile device when you first visit a website or page. The cookie will help the website, or another website, to recognise your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way.
There are many functions cookies serve. For example, they can help us to remember your username and preferences, analyse how well our Website is performing, or even allow us to recommend content we believe will be most relevant to you.
Certain cookies contain personal information – for example, if you click “remember me” when logging in, a cookie will store your username. Most cookies won’t collect information that identifies you, and will instead collect more general information such as how users arrive at and use our Website or a user’s general location.
2.         What sort of cookies does Soberistas use?
Generally, our cookies perform up to four different functions:
Essential cookies
Some cookies are essential for the operation of our Website. For example, some cookies allow us to identify subscribers and ensure they can access the subscription only pages. If a subscriber opts to disable these cookies, the user will not be able to access all of the content that a subscription entitles them to.
Analytical and/or performance cookies
Some cookies analyse how our visitors use our Website and monitor performance of the Website. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This can help us to improve the way our Website works by ensuring that users are finding what they are looking for easily. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or services that we think will be of interest to you based on your usage of our Website.
Functionality cookies
We use functionality cookies to allow us to remember your preferences for your return visits to our Website. For example, cookies can save you the trouble of typing in your username every time you access our Website. This also enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Behaviourally targeted advertising cookies
We use cookies to record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose anonymously. We do not tell third parties who you are.
Some site specific cookies that we use are as follows: 
 
XSRF
Meaning: Cross-site request forgery
Usage: Preventing cross-site request forgery. 
In Basic Non-Jargon Terms: Used for user security
 
Laravel_Session
Meaning: User session
Usage: Serving up personalised content for each user. This is unique per user and allows us to know if the user is valid and logged in
In Basic Non-Jargon Terms: Used for user security and delivering user-specific content
3.         Google cookies
We also use Google analytics cookies.  These collect anonymised data and so do not collect your personal data. They help us to understand how members use the site, which enables us to improve our services. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our Website is used to create reports about the use of our Website. Google will store and use this information. Google's privacy policy is available at www.google.com/privacypolicy.html
More information can be found on Google Analytics here – https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie/usage.  
We may publish Google Adsense interest-based advertisements on our Website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour across the web using cookies. You can view, delete or add interest categories associated with your browser using Google's Ads Preference Manager available at www.google.com/ads/preferences. You can opt-out of the Adsense partner network cookie at www.google.com/privacy_ads.html. However, this opt-out mechanism uses a cookie, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you should use the Google browser plug-in available at www.google.com/ads/preferences/plugin.
4.         Can a website user block cookies?
The first time you access our Website, you should have seen an overlay which explained that by continuing to access our Website, you are consenting to our use of cookies.
Please remember that if you do choose to disable cookies, you may find that certain sections of our Website do not work properly. For example, you may have difficulties logging in or viewing articles.
If you are concerned about behaviourally targeted advertising cookies (which serve you advertisements based on your use of Soberistas and other websites), users based in the European Union can visit www.youronlinechoices.eu and users based in the US can visit www.aboutads.info/choices to opt out of these third party cookies.
You can disable cookies using your browser. The way in which you disable cookies will depend on the type of browser you use. Please refer to your browser information for further guidance.
5.         More Information
More detail on how businesses use cookies is available at www.allaboutcookies.org.

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