Morley Digital Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://www.impressivethemes.net (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Morley Digital Limited, a limited company registered in England under company number 10112662, whose registered address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom and whose main trading address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom;
2.1 Our Site is owned and operated by Morley Digital Limited, a limited company registered in England under company number 10112662, whose registered address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom and whose main trading address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5.2 date of birth;
5.4 business/company name;
5.5 job title;
5.7 contact information such as email addresses, billing address and telephone numbers;
5.8 demographic information such as post code, preferences and interests;
5.9 financial information such as credit / debit card numbers;
5.10 IP address (automatically collected);
5.11 web browser type and version (automatically collected);
5.12 operating system (automatically collected);
5.13 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products and services for you;
6.2.6 Replying to emails and support requests from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the bottom of said emails);
6.2.8 Market research;
6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or post with information, news and offers on Our [products]. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 Third parties (including CloudFlare, Clicky Analytics, Google Analytics and MailChimp) whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.6.1 Billing/purchase details (including name, address, telephone and email address of purchasers, as well as details of items purchased) will be stored indefinitely to enable us to determine who has the legal right to use our software;
6.6.2 Personal details of subscribers to our mailing list (including name and email address) will be stored indefinitely. Even in the case of those who later unsubscribe from our communications, it may be necessary to retain their data in order to ensure that they are excluded from future communications.
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
7.2.1 Ensuring that any data processors outside of the EEA that we use are fully compliant with the requirements of the GDPR.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Utilising SSL technology to encrypt all data transferred between your web browser and our website;
7.4.2 Ensuring that the software used on our website to store and process your data is regularly updated;
7.4.3 Regular scheduled website security scanning to ensure that our website is secure and your data is protected.
8.1 We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.3 The third party data processors used by Us and listed below are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
8.3.1 Zapier (Zapier, Inc., a Delaware corporation located at 548 Market St #62411, San Francisco, CA 94104-5401) – Zapier is a tool that automates the transfer of data (including personal information) between our various systems and data processors. They are fully compliant with the requirements of the GDPR (further Zapier GDPR compliance information is available here) and a data processing agreement is in place;
8.3.2 Clicky Analytics (Roxr Software Ltd, 10883 SE Main St #201, Milwaukie, OR, 97222) – Clicky Analytics provide website analytics services. They are fully compliant with the requirements of the GDPR (further Clicky Analytics GDPR compliance information is available here) and a data processing agreement is in place;
8.3.3 Google G Suite (Google LLC [formerly known as Google Inc.], Google Ireland Limited, Google Commerce Limited, Google Asia Pacific Pte. Ltd or Google Australia Pty Ltd) – Google G Suite provides email, online applications and cloud storage services. They are fully compliant with the requirements of the GDPR and certified to the EU-U.S. Privacy Shield Framework (further Google G Suite GDPR compliance information is available here). A data processing agreement is in place;
8.3.4 Google Analytics (Google LLC [formerly known as Google Inc.], Google Ireland Limited, Google Commerce Limited, Google Asia Pacific Pte. Ltd or Google Australia Pty Ltd) – Google Analytics provides website analytics and visitor tracking. They are fully compliant with the requirements of the GDPR and certified to the EU-U.S. Privacy Shield Framework (further Google G Suite GDPR compliance information is available here). A data processing agreement is in place;
8.3.5 SendGrid (SendGrid, Inc.) – SendGrid provide email delivery services for automated emails sent via our customer membership system. They are fully compliant with the requirements of the GDPR and certified to the EU-U.S. Privacy Shield Framework. A data processing agreement is in place;
8.3.6 MailChimp (The Rocket Science Group, LLC d/b/a MailChimp) – MailChimp provide mailing list management and email delivery services. They are fully compliant with the requirements of the GDPR and certified to the EU-U.S. Privacy Shield Framework. A data processing agreement is in place;
8.3.7 Cloudflare (Cloudflare, Inc,) – Cloudflare provide content delivery network services, DDoS mitigation, Internet security and distributed domain name server services, sitting between website visitors and our hosting provider. They are fully compliant with the requirements of the GDPR and a data processing agreement is in place;
8.3.8 FastSpring (Bright Market, LLC d/b/a FastSpring) – FastSpring are an authorised reseller of our products and services and handle all purchases of our software products and liceneses. They are fully compliant with the requirements of the GDPR and certified to the EU-U.S. Privacy Shield Framework (further FastSpring GDPR compliance information is available here).
8.3.9 Dropmysite (Dropmysite Pte Ltd.) – Dropmysite provide an offsite backup service for our websites and databases.
8.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9.2 In the event that any of your data is to be transferred in such a manner, you may not be contacted in advance and informed of the changes.
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details via our support ticket system, or using the contact details below in section 14.
13.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for the purposes of collecting anonymised usage statistics, measuring the success or our advertising campaigns, etc. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
13.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.4 You will be shown a notification when Our Site first places cookies on your computer or device. By continuing to browse our site, you are deemed to consent to the use of these cookies.
13.5 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.6 The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|These are used by our ecommerce and membership system to ensure you can only access to subscription-only areas of our website if you have a valid subscription.
These are strictly necessary cookies and as such, some parts of the website may not work if you do not allow these to be set.
|Our content management system, WordPress, sets a number of cookies which can be used to customize your view of the website. These cookies do not contain any personal data.||Yes|
|PHPSESSID||PHP: This is a simple token used by PHP applications, such as this website, to identify your unique session. Typically used to maintain the integrity of your session while transacting information with a website (accessing secure areas, forms submissions etc). It does not store any personal data and is deleted when the visitor closes their browser.||Yes|
|OSTSESSID||This is a simple token used by our support ticket application, to identify your unique session. It does not store any personal data and is deleted when the visitor closes their browser||Yes|
|cookieconsent_dismissed||Used to determine when the cookie consent banner has been dismissed.||Yes|
|__cfduid||The __cfduid cookie is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. For example, if the visitor is in a coffee shop where there are a bunch of infected machines, but the specific visitor’s machine is trusted (e.g. because they’ve completed a challenge within your Challenge Passage period), the cookie allows us to identify that client and not challenge them again. It does not correspond to any user ID in your web application, and does not store any personally identifiable information.||Yes|
13.7 Our Site uses analytics services provided by Google Analytics and Clicky Analtycs. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the [products] AND/OR [services] offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.9 The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|_ga||First party||Google Analytics||Used to distinguish users.|
|_gat||First party||Google Analytics||Used to throttle request rate.|
13.10 Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
13.11 To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
13.12 You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
13.13 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.