Our Privacy policy

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Table of Contents

  1. Welcome Notice
  2. Some Definitions
  3. What we do and where we are
  4. Your personal Information
  5. What Personal Information do we collect
  6. The Collection and Use of Personal Information:
  7. With Whom do we share and disclose your data:
  8. How long do we keep your personal information
  9. How we protect your data:
  10. Warrants and Policy Enforcement:
  11. Privacy Policy – ROGAN COLES WORKSHOPS:
    1. Your Account:
    2. Data Collection:
    3. Payments:

WELCOME:

Welcome to the ROGAN COLES WORKSHOPS Privacy Policy page.

We care deeply about the privacy of our visitors and users and any Personal Information that may be shared with us. We are fully committed to protecting your Personal Information. We have put this Privacy Policy together to help define how we may use the Personal Information that we may collect in the course of managing our business and the services we provide – this in compliance with prevailing data privacy laws. 

We have created this Privacy Policy document so as to demonstrate our commitment to your privacy and to the protection of your Personal Information. This policy describes how we collect and use Personal Information and the rights and choices available to you as one of our visitors and, possibly, a signed up user of any of our services.

This Privacy Policy governs the manner in which we collect, use, maintain and disclose personal and non-personal data gathered from unregistered visitors and registered users in connection with their access to and the reasonable use of the ROGAN COLES WORKSHOPS website.

The purpose of this Privacy Policy is to provide you with a clear explanation as to how, when and why we collect and use your Personal Information. This Privacy Policy is not intended to override the terms of any contract you may have with us, nor any rights you may otherwise have under any locally applicable data privacy laws.

We encourage you to please read this policy and to ensure you fully understand our practices in relation to the collection and use of your Personal Information before you access or use any of our on-line Services. If you have read and fully understand this Privacy Policy and still you remain opposed to our business practices and the management of your privacy, you have a choice: please leave this website immediately and avoid or discontinue any further use of our Services. If you have any questions or concerns regarding this Privacy Policy, please contact us at privacy@rogancoles.photos.

That said, in the course of our business it is necessary for us to collect Personal Information [identifying and non-identifying information]. We require this information to track visitors visiting our website, to verify the identity of our Users, to protect our customers and to ensure the integrity of the Services we provide. We also collect Personal Information when we respond to communications with individuals who have contacted us in the ordinary course of our business.

For the most part, our website is public and can be visited anonymously. We collect personally-identifying information from you only if you voluntarily submit such information to us. You can always refuse to supply personally-identifying information, the caveat being, this may prevent you from engaging in certain website related activities and/or accessing some of the services and content we offer.

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SOME DEFINITIONS:

  1. USERS – A USER refers to an individual who has signed up to post a comment, a review, to subscribe to a service or to make an enquiry about or from our WEBSITE. For the remainder of this document such a visitors to our WEBSITE will be henceforth referred to as “you”, “your” and/or “User”.
  2. VISITORS – A VISITOR is defined as an individual who maybe casually visiting this website with no other intent other than browsing its contents – henceforth referred to as a “visitor” or “visitors”.
  3. ROGAN COLES and through his trading entity ARGENT PHOTOS will henceforth be referred to as “us”, “our”, “we”, “Argent” and/or “Rogan”.
  4. THE ROGAN COLES WORKSHOPS website will henceforth be referred to as the “WEBSITE”.
  5. PERSONAL INFORMATION: There’s a subtle but distinct difference between “Personal Information” and “Personal Data”. The term “Personal Data” is wide ranging and broader is scope. By way of example, a company signing up a new staff member would be collecting “Personal Data” – as in resumes, medical records and whatever. In accessing our WEBSITE, we may only collect “Personal Information” – which is basically a subset of “Personal Data”. In this Privacy Policy document, we will further expand on defining our meaning and interpretation of the term “Personal Information”, this within the framework of the prevailing international privacy policy guidelines and legislation. Local privacy policy guidelines and legislation may vary from country to country.
  6. In further defining the term “Personal Information” there are 2 types of information that matter:
    1. “Non-Personally-Identifying” information – the reference here is to data of the sort that is part of any web browser/web server interaction. Typically, this information may include a visitor’s IP address, browser type, computer or mobile operating system, referring sites, pages visited and the date and time of each visit. There is little, if any personal identifying information here that actually refers to a specific person.
    2. “Personally-Identifying” information is information that suitably identifies and is specifically attributable to an individual. Such “Personally Identifying” information is voluntarily submitted any time a visitor signs up to use any one of our on-line services. This data usually includes a name or user-name, an email address and, if you are looking to make a purchase, all the necessary information required to make any such a transaction. In this sign-up process, the visitor then becomes an identifiable USER of this WEBSITE and its on-line services.
  7. USER ID – A USER ID is created when setting up a new USER account. In its most basic from, this User ID usually comprises of a name or user-name and an email address. While we encourage the use of real names, a user-name can be a moniker of sorts. Please review or Comments Policy for more details – https://workshops.rogancoles.photos/comments-policy/
  8. IP [INTERNET PROTOCOL] ADDRESSES – an IP address is series of numbers [IPv4] or a mix of numbers and letters [IPv6]. The series of numbers looks something like this: 198.162.0.1. The IP address in this notation is usually location specific. However and generally, this IP address is not User specific. For example, if someone connects to our WEBSITE from an Internet cafe in New York say and then, in the following week, that same person connects up from another Internet cafe in Paris – while the country locations maybe known, we won’t necessarily know who the visitor was.
  9. COOKIES – A “cookie” is a “token” – a sting of data – that is left on a visitor’s computer when visiting a website. In the example above, if the said visitor accepts one of our web server cookies, I may well be able to “track” who that visitor was – this depending on that User’s interaction with this WEBSITE. There is indeed, a big difference between “tracking” and “identifying”. In the example above, almost all the information from the above visit is of a “non-personally-identifying” nature.
  10. CLIENTS AND CUSTOMERS – Our reference for the term CLIENT refers to third party who maybe a person or a company doing business with ARGENT PHOTOS and its representatives. This business will quite likely be outside the scope of this WEBSITE and its business.
  11. The term CUSTOMER is said to refer to a person or business that does a walk-in, over-the-count business transaction. Such business usually falls outside the scope of this WEBSITE and its business. Thus, and for the purposes of this Privacy Policy document, we prefer “USER” and “VISITOR” [or the plurals thereof] as being synonymous with this WEBSITE and an integral part of the Services we provide.
  12. INTERNET SERVICE PROVIDERSINTERNET SERVICE PROVIDERS are typically defined as the providers of web or Internet based services. Typically these web based services may include website hosting and related services, search engine service, payment gateways, CDNs [Cloud Networks] and others. In fact, these Internet Service Providers together with a whole host of other web services provide the functionality that brings us together – as in you, the VISITOR or USER and the services we provide on this WEBSITE. There’s no getting passed them.
  13. These and other details are further elaborated upon within in this policy document.

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WHAT WE DO AND WHERE WE ARE:

  1. Our Business:
    1. ROGAN COLES WORKSHOPS is a promotional vehicle created by Rogan Coles and managed through his trading entity, ARGENT PHOTOS.
    2. Rogan Coles – through his trading entity ARGENT PHOTOS [at this stage a sole proprietary business entity] – is in the business of photography and digital media. Rogan’s websites have been created and set up to actively promote his photography, the photography services he has to offer and to sell his work – be this in the form of wall art, prints, books and/or digital downloads.
    3. As an adjunct to this activity, Rogan also engages with audiences through blog posts on matters relating to photography and his work. As a result, people from all around the world visit these various websites and may engage with them in one manner or another. As part of this engagement, you leave behind a record of sorts. This just the way the Internet works.
    4. The rogancoles.photos websites [collectively referred to as “Argent” throughout this document] currently refers to the ROGAN COLES PHOTO ARCHIVE website, the ROGAN COLES PHOTO SHOP website, the LOST YEARS PROJECT website and this, the ROGAN COLES WORKSHOPS website.
  2. Our Address:
    • 28 Queen’s Road
      Central
      Hong Kong.
  3. How to contact us:

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YOUR PERSONAL INFORMATION:

  1. Consent to Collect:
    1. We collect Personal Information from USERS who create accounts with us.
    2. In setting up an account – to either post comments, to shop with us or to post product reviews – we ask for your consent before starting the account creation process with a check box on the comment or account form. A link to this Privacy Policy page is provided as part of this account creation process.
    3. The legal basis for us to collect your data is to be able to provide you with the services we offer and for you to access to this website.
    4. By providing us with your Personal Information, you are consenting to our use of your Personal Information and this in accordance with our Privacy Policy. This would include the transfer of your Personal Information from your jurisdiction, across international boundaries to other jurisdictions anywhere in the world as permitted by local law. The meaning here is this, you might be say, in the USA. My web server is say in Europe and, I am here in Hong Kong. You sign up where you are and I receive your Personal Information where I am. Again, this is the nature of the Internet making all this possible.
    5. While some of this international jurisdictions may be deemed not to have data privacy laws that afford an equal level of protection for your Personal Information as those laws legislated at the direction of the European Union, however, please be assured that we will continue to adhere to the principles as stated in this Privacy Policy and the applicable laws in connection with any Personal Information we may collect. We will endeavor to preserve the integrity, confidentiality, and security of your Personal Information and afford such Personal Information adequate levels of protection.
  2. What rights you have over your data:
    1. If you have an account with us – or, if you have signed up to post comments, etc. – on request, a file containing any personal data we may hold on you, including any data you have provided to us, will be sent to you by email – to either the address we have for you on file or, to any another verifiable email address as provided by you.
    2. We will service this request within 30 days.
    3. To facilitate such a request, we may ask you to adequately identify yourself.
    4. You may request that your data be anonymized which we will do within 30 days.
    5. You can also request that we erase any personal data we hold about you. However, this may not include any data we are obliged to keep for administrative, legal, or security purposes.
  3. Data integrity
    • We will only process and retain Personal Information in a way that is compatible with and relevant for the purpose for which it was collected and/or authorized by you. To the extent necessary for those purposes, we will take reasonable steps to ensure that this Personal Information is accurate, complete, current and reliable for its intended use and/or purposes.

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WHAT PERSONAL INFORMATION DO WE COLLECT:

  1. Directly:
    1. When a visitor contacts us directly for some specific reason or other – usually by email. So, we end up collecting names and email addresses.
    2. When creating an account with this website – here we collect a new USER’s full name, a display or user-name, email address and password.
    3. When a new user registers to post a comment or a review. In the process of setting up an account with us, here we collect the USER’s full name, display or user-name, email address and password.
    4. When editing, managing and/or updating an account – here we collect user-name, email address and password information.
    5. When signing up to post a comment or to write a review on this website – here we collect user names and email addresses as well as the User’s IP address and browser user agent string – this to help with spam detection.
    6. When wanting to make a purchase or applying a payment – here we collect names, email addresses, contact and/or shipping addresses, financial information and other contact details.
    7. When registering for or signing up to subscribe to a service, to a list, to register a connection or other process whereby Personal Information is required to receive or access something, including a transaction.
    8. When supplying scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents) – generally for purposes on identification verification,
    9. When an individual supplies us with goods and/or services.
  2. Indirectly:
    1. Any time a visitor visits this website, that visit is registered in some fashion or other. The data left behind on our server typically includes IP addresses, the date and time of the visit, browser type, OS type and a history of the pages visited.
    2. Details regarding connected third party accounts (such as the e-mail or user-name for a connected PayPal, Google or Facebook account),
    3. Cookies – for the purposes of this document, we consider data collected by cookies as “indirect”, as in something that usually happens in the background.
  3. Cookies:
    1. A “cookie” is a token – a “string” of information – that our web server “stores” on visitor’s web browser when visiting and accessing this webste. Put simply, on a return visit and through this “cookie”, our web server kind of understands that you’ve visited our website before. We may use these “cookies” to identify and track visitors while browsing this website. No big deal.
    2. The main purpose of a “cookie” is to help enhance your “user experience” and to help us have a better understanding of our website and the services we provide.
    3. These cookies are for your convenience – so that, for example, you won’t have to fill in your details again when you want leave another comment.
    4. In posting a comment or review on our website, you now have a choice to “opt in” – this via a check box at the bottom of the form. In doing so, your name, email address and website are saved in a “cookie”.
    5. The lifespan of cookies varies. Some are short lived – as in terminating when you either sign out or when you shut down your web browser. Others may remain for longer and may have a lifespan of a year or longer. Thus:
      1. If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
      2. When you log in, several cookies are set up to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year.
      3. If you select “Remember Me”, your login will persist for two weeks.
    6. Opting Out– of course, you may choose to set your web browser to refuse cookies or, to alert you if a cookie is about to be set. This is something you can either choose to accept or refuse. In refusing to accept cookies, certain of our website’s features and services may not be available to you or, may not function as intended. For example, on the downside, you may end up having to repeatedly reenter your user information when wanting to post a comment or review. The choice is entirely yours.
    7. Please Note: – in “clearing” your web browser’s data, you may also be clearing all the cookies hosted by your web browser. Sometimes this may be “unintentional”. In this regard, please check your settings.
  4. Media:
    • If you upload images via your posts to this website, you should avoid uploading images that may include embedded location data (EXIF GPS). Visitors to the website can download and extract any location data from third party images placed on or posted to this website.
  5. Embedded content from other websites:
    1. In your posts and while uploading other third party articles and posts to this website, please note that they may include embedded content (e.g. videos, images, content, etc.). Embedded content from other websites behave in the exact same way as if you, the User, has visited that other website.
    2. These other websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
  6. Additional Data Collection Points

    As there are many varying circumstances in which Personal Information can be collected – both electronically and physically – we will endeavour to ensure that you, the USER, are always aware of how and when your Personal Information is being collected. Thus, without limitation, the types of information we may collect includes:

    1. Personal Details – We may collect personal details such as the User’s name and website user name. Collecting specific information relating to age, gender, nationality and the like are not within our remit.
    2. Personal Contact Information – We may collect personal contact information such as a User’s email address, billing and/or shipping addresses and phone numbers. Collecting other types of contact information such as fax numbers, social media references and the like are not within our remit.
    3. Personal Financial Information – We may collect a User’s financial information such as banking details and/or credit card information – this as part of any business being transacted with us. With permission, this financial information maybe used to allow us to provide you with any other business related services we may have to offer.
    4. Photos and Photo ID – as one of our Users, we will not ordinarily ask you for a photo of yourself. If you use an image of your likeness as part of your avatar, this is something that you offer and this usually via a third party [linking to an avatar website]. Regarding Photo ID – there may be that rare occasion when we may require a Photo ID to verify your identity – this usually in regard with any financial transactions we may have with you – typically the use of credit cards, etc.
    5. Social Media apps – We may collect twitter, Facebook and/or other social media User-names if you, the User, use these social media networks to connect with this website. Included are single sign-on features such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like” button, the “Share this” button or other interactive Social Media apps. These Social Media apps may collect information such as your IP address, the pages you may have visited on our website. They may also set cookies to facilitate their operations. These Social Media apps are hosted elsewhere and, as such, are governed by their privacy policies and not ours.
    6. Location Information – Other than through any standard Internet engagement, we do not use any other technologies to determine your location when you use or visit this website.
    7. Professional Information – Other than such information that is “volunteered” to us, we do not collect any professional information such as the work you do, where you may work and so forth. This sort of information is beyond our remit.
    8. Statistical Information – Through various means, we use various web analytical tools to assess the behavior and engagement with this website. Again, and as mentioned above, this sort of data is generally “non-personally-identifying” information and is generally aggregated and for internal use only.
    9. Other Personal Information – We may collect other “personally-identify” information about you which will be maintained in accordance with this Privacy Policy.
    10. For the avoidance of doubt, any Non-Personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as any such connection or link exists.
  7. Data Collection and Minors
    1. “MINORS” – a definition: Around the world the term “minor” and the ages defined vary from one jurisdiction to another. For the purpose of this website and for our Privacy Policy, we take the term “minor” to mean any person “under the age of consent” as defined by law – however this varies from jurisdiction to jurisdiction.
    2. While this website is a general audience website, this website and its contents are NOT directed towards minors who are under the age of 13.
    3. Typically, there is nothing that we provide here on this website – this in terms of content, the services we offer and/or the discourses we may engage in – that is either compelling or of any particular interest to a minor.
    4. We do not knowingly collect Personal Information from minors.
    5. If we or any of our Internet Service Providers or other affected parties become aware that a child or minor has provided us with Personal Information and this without parental consent, this information will be deleted from our services and databases forthwith.
    6. Parental or Guardian’s consent – while we hope this won’t ever become necessary, we may ask for written proof and other documentation in this regard.
    7. If you have any queries or information about Personal Information that may have been submitted by a minor, please email us.

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THE COLLECTION AND USE OF PERSONAL INFORMATION:

We collect such Non-personal and Personal Information for the following purposes:

  1. Our Business Operations – Other than for the stated purposes for which your Personal Information was collected, we may use that Personal Information to enable us to operate our business, especially as it relates to you the USER. This may include:
    1. Verifying your identity,
    2. To provide and operate the on-line services and facilities we offer.
    3. To permit you to engage and use the services and facilities provided by our website – to post comments, to shop and so forth,
    4. To communicate with you about:
      1. your relationship with us,
      2. announcements, notifications and updates about our company and the services we offer,
      3. polling your opinions through surveys or questionnaires,
      4. our own marketing or promotions and/or competitions we may be running including determining a participant’s eligibility, to contact winners and to grant prizes and other benefits,
      5. our goods and services and,
      6. if necessary, to enforce our USER AGREEMENT, any other agreements we may have with you or any pending legal action.
    5. Thus, the first time that you provide us with registration information through our website, you may be offered the opportunity to subscribe to and/or receive additional information about our services.
    6. Customer Service Improvements – The Personal Information you provide may help us respond to your customer service requests and support needs more efficiently.
    7. Personalizing User Experience – We may use Personal Information [as aggregated] to understand how our Users, as a group, use the services and resources we provided this website.
    8. Site Improvements – We may use any feedback you provide to improve our products and services – this based on Visitor and User common or personal preferences, experiences and difficulties. These improvements also include enhancing our data security and fraud prevention capabilities.
    9. Payments. We use the Personal Information Users provide about themselves when placing an order only to provide service to that order. 
    10. The supply of goods and the provision of services between yourself and Argent.
    11. Emails – We may use your email address to send you information and updates pertaining to your order. Your email address may also be used to respond to your inquiries, questions, and/or other requests.
    12. FTC e-mail compliance guidelines allows us to send you transactional and relationship e-mail without offering you the opportunity to opt-out of receiving these types of e-mail.
    13. Subscriptions and Mailing list:
      1. If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, etc.
      2. Each commercial e-mail that we send to you will offer you the opportunity to opt-out of continuing to receive such messages. This may take up to 10 business days to process your opt-out requests.
      3. If at any time you would like to unsubscribe from receiving future emails, you may do so by contacting us via our contact form.
    14. For these purposes, we may contact you via email, by phone, using text messaging services or by postal mail.
    15. We do not share this information with outside parties except to the extent necessary to provide the service.
  2. Our Site Operations:

    To better understand how you and visitors engage with this website and how you and other visitors use the services we provide, we use variety of web analysis tools and services. These tools include our web server logs and the services provided by Google [Google Search Console and Google Analytics] and by Microsoft [Bing web tools].

    1. PLEASE NOTE – the data and information we use here is generally “non-personally-identifying” data. This analysis generally involves:
      1. determining where our visitors come from [location based on IP addresses],
      2. the pages visited,
      3. the duration and engagement with those pages,
      4. whether the visitors are new or repeat visitors,
      5. how visitors were referred to this website – by search engine, via social media and the like,
      6. and then, other minor details such as browser type [Chrome, Edge, Firefox, etc], OS type [Apple, Android, Windows, etc], date and time of visit and so forth.
      7. there’s a bit more but, the above items are our more crucial data metric points.
      8. to reiterate, there is nothing here that says anything specifically about you in person.

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WITH WHOM DO WE SHARE AND WHAT DO WE DISCLOSE:

  1. To qualify, in the process of “sharing” data, we do not actually “hand over”, rent or sell any information or data to other third parties. We are, however, “co-dependent” on various Internet and web based providers, services and vendors and the facilities they provide. These include:
    1. Our current web hosting company. This company is based in the USA and we use it’s servers based at a data-centre located in Singapore,
    2. Stripe and Paypal are our payment gateway providers and through them, we process your payments. Both companies are headquartered in the USA,
    3. Google Inc. – they provide web browser, web search engine and web analysis tools and services. They are headquartered in the USA and
    4. Microsoft Inc. – they provide web browser, web search engine and web analysis tool and services. They are headquartered in the USA.
  2. We also use several automated decision making and/or profiling services, namely:
    1. Automattic’s Akismet – this is anti-spam service plugin. The service scans email addresses, web links and keywords in comments and posts and looks for matches in its database. If a match is found the comment or post is flagged for further review. Please review our comments policy for more details.
    2. Automattic’s Gravatar service – an anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. After approval of your comment, your profile picture is visible to the public in the context of your comment. The Gravatar service privacy policy is available here: https://automattic.com/privacy/.
    3. We use several security plugins that scan IP Addresses and other non-personally-identifying metrics to secure the services we provide.
  3. Our website administrators can also see and edit this information.
  4. Disclosure of Personal Information:
    1. Purpose – We will not use any Personal Information other than for the purpose for which it was collected. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted to us and usually via our website.
    2. Non-Disclosure – Other than the information made available to visitors and Users to this site – such as a user-name or name – we will not disclose any Personal Information or the nature or the extent or value of the relationship between you and Argent to any unrelated third parties under any circumstances unless, otherwise directed, by a court of law.
    3. Disclosure – There may be some circumstances where we must disclose Personal Information. These may include but not necessarily limited to:
      1. complying with a subpoena or court order;
      2. cooperating with law enforcement and/or other government agencies;
      3. establishing or exercising our legal rights;
      4. protecting the property or safety of our business, brand, any contractors, vendors, suppliers, and customers;
      5. in defending legal claims;
      6. helping with internal and external investigations; or
      7. as otherwise required by law or permitted by law.

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HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION:

  1. How long do we retain your data?:
    1. We may retain your Personal Information for as long as your USER account with us is active, as indicated in this Privacy Policy or, as otherwise needed to provide you with our Services or, unless a longer retention period is required or permitted by law.
    2. If you, as a USER, leaves a comment, that comment and its metadata are usually retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
    3. For USERS that sign up and register themselves on our WEBSITE, we store the Personal Information provide in the User’s profile.
    4. All USERS can review, edit, and/or delete their User Profile and Personal Information at any time. The exception is the User’s on-line User-Name – this is to prevent it’s reuse by either you or a third party. To change a User-Name, a new user account will have to be created and the old User Account deleted
    5. We may continue to retain such Personal Information even after you have deactivated your User Account with us and/or cease to use any of our Services – this as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, to prevent fraud and abuse or to enforce our agreements and/or protect our legitimate interests.
    6. We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.
    7. Regarding some financial transactions, by law, we may be required to keep this data on file for a statutory period of time before we can deleting and destroying it.

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HOW WE PROTECT YOUR DATA:

  1. The safety and security of Personal Information, for us, is an on-going concern. As we take our privacy and the security thereof seriously, we do the same with yours.
  2. We are aware of the challenges and vulnerabilities presented to us while using the Internet as medium of communication and to transact business. We adhere to the principles outlined in VISA’s “Account Information Security” [AIS] programme. We also work where we can to enhance the security of our services and to reduce the risks thereof.
  3. Physical Facilities:.
    1. In our offices:
      1. We take all reasonable precautions to protect Personal Information from any unauthorized access to our space and facilities. This includes appropriately securing our physical facilities and our computer networks.
      2. We have adopted what we feel to be effective data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure and/or destruction of your Personal Information. This may include your User-name, password, transaction information and other data we may have stored.
  4. Beyond our offices:
    1. Web Hosting – At the moment we run our own VPS [Virtual Private Server]. While a vast improvement on shared web hosting, this is the Internet. Our server is continually being tested and challenged by hostile entities. That said, we make every reasonable effort to ensure that we have implemented all the necessary physical, electronic and procedural security measures to assist with safeguarding your Personal Information and to help protect against unauthorized access and inadvertent disclosure.
    2. File transfer – we connect with our web servers using Secure FTP (SFTP).
    3. Encrypted Data – All personal data exchanges between our website, our Services and you takes place using SSL and TLS. This means that any exchanges between you and our services is secured over the HTTPS protocol [Secure Socket Layer] and is encrypted using Transport Layer Security.
    4. Internet Security – The security of on-line transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Any person providing information to us via the Internet or by post does so at their own risk. We cannot accept responsibility for the misuse or unauthorized access to Personal Information where the security of information is not within our control.
    5. Furthermore, we cannot promise you, and nor should you expect, that your Personal Information, personal searches, and other communications will always remain secure. From your side, you ought to take care how you handle and disclose your Personal Information or any username or password that you are required to use to access our website and the services we provide to you.
  5. What data breach procedures do we have in place:
    1. Web Logs – Our web server keeps a log of all activity on that server. These logs are accessed and reviewed on a regular basis.
    2. Security Plugins – We have security plugins that alert us to any suspicious web activity.
    3. Updates – CMS – Our CMS platform and all associated plugins are updated as soon as updates become available.
    4. Updates – Hosting – We update our servers as soon as new server patches and updates are made available.
    5. Back-ups – We back up our web server, our websites and any related services on a regular basis.
    6. Off-site Data Storage – On a weekly basis we pull and download a complete log and website backup for our own records.
    7. Data Breach – In the event that there has been a breach our Services and if our User data has been compromised, you will be informed of such a breach, the nature of that breach, what data has been compromised and what remedial action should be taken once we have assessed the nature of that breach.

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WARRANTS AND POLICY ENFORCEMENT:

  1. Warrants:
    1. You warrant that you are the person you say you are. If not, we will take whatever remedial actions that maybe necessary, this as per this Privacy Policy and our Terms and Conditions of service.
    2. You warrant that you are above the “age of consent”. We do not knowingly collect Personal Information from minors. At no time should any minors be signing up to our services and providing us with any of their Personal Information.
    3. This Privacy Policy document has been put together in good faith, based on various international guidelines, recommendations and texts.
    4. We reserve the right to modify this Privacy Policy at any time and without notice. 
    5. Changes and clarifications will take effect immediately upon their posting on this page. We encourage you to frequently review this page so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or may disclose it. 
    6. If we make any material changes to this policy, we will endeavour to post notices of any changes on our blog, on this page and, if needs be, to inform all our registered Users by email.
    7. From time to time, we may send you important notices, such as changes to our terms, conditions and policies. Because this information is important to your interaction with us, you may not opt out of receiving these communications.
    8. It is the USER’s responsibility to provide us with accurate and truthful Personal Information. We cannot be held liable for the veracity of that information or the lack thereof. We take and accept your Personal Information at face value.
    9. If for any reason a USER cannot update his or her own Personal Information, we will correct any errors in the USER’s Personal Information within 30 business days of receiving notice from you about such errors.
    10. If we become aware of any unauthorized access to an individual’s Personal Information, we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
    11. This notice falls under the EU’s GENERAL DATA PROTECTION REGULATION of 2018
    12. Complaints and disputes:
      1. If a USER has a complaint about our handling of their Personal Information, they should address their complaint to us in writing using our contact form
      2. If we have a dispute regarding a USER’s Personal Information, we both must first attempt to resolve the issue directly and amicably between us.
    13. Your acceptance of these terms – By using this Site, you signify your acceptance of this Privacy Policy and our Terms and Conditions of service. If you do not agree to these policies, please do not use the ROGAN COLES WORKSHOPS website. Your continued use of our website following the posting of changes to this policy will be deemed your acceptance of any changes we have made.
    14. Contacting us – If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us using our Contact Form
  2. Policy Enforcement:
    1. At this stage we use a self-assessment approach to assuring compliance with this Privacy Policy.
    2. Periodically we will verify that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, that it is accessible and in conformity with the EU privacy principles.
    3. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints or disputes regarding the use and disclosure of Personal Information in accordance with the principles espoused here
    4. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resourced mechanism) as a third party resolution provider.

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Links to our other policy pages:

Last modified: 2021/02/18

(GDPR).