Welcome to the Clan Mackenzie Initiative and our website clanmackenzie.org. For your current and any further visits to our website, we would like to inform you about data collection, processing and use when visiting and using our service.
Background
This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided.However, to achieve this objective we would like to explain you the following four concepts.
a) What is Personal Data?
“Personal Data” is any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie or an IP Address) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) What is Processing?
“Processing” means and covers virtually any handling of data.
c) What law applies?
We recognize the current lack of consistent and comprehensive Federal and Indiana State Privacy legislation and have as such voluntarily adopted the current gold standard deriving from the EU`s General Data Protection Regulation (“GDPR”). Thus, we act as the data controller in accordance with the GDPR. Whilst it is expected that current legislative uncertainty is to be resolved in due course, we would like to ask you to regularly check this policy for any changes.
d) The Person responsible (“Data Controller”)
The person(s) responsible for the processing of Personal Data is the Clan Mackenzie Initiative. If you have any questions about the processing of your Personal Data, please contact jared@clanmackenzie.org .
General Principles
a) Purpose and legal basis of processing
In accordance with the GDPR we need to have both a purpose and a legal basis to process Personal Data. The purposes are:
• providing the website and its functions and contents,
• responding to contact requests and communicating with our customers,
• providing our services, and
• security measures.
Of course, we can only do that if we have at least one of the following legal bases or in other words lawful reasons to do so. Unless specifically described below, we typically link the above purposes to one of the following:
• consent,
• to fulfill our services and carry out contractual obligations,
• to fulfill our legal obligations, and
• to protect our legitimate interests.
b) Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us.
You can recognise an encrypted connection if the address line of your browser contains a “https://” instead of a “http://” and also has a lock symbol. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.
Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
c) Retention and Storage
We retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with Indiana’s Statutory Retention Periods.
d) Minors
Persons under the age of 16 should not transmit any Personal Data to us without the consent of their parents or legal guardians. We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
e) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
f) Do Not Sell
We do not sell your Personal Data.
g) Special Category Data
Unless specifically required and consent is obtained, for a particular service, we do not process data that is revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data.
h) International Transfer
In the course of our website operation, we process data. We usually do not transfer Personal Data to countries outside the USA. However, if we do, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.
i) Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services for example with our web host (see below), b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings or proceedings at home or abroad or to fulfill our legitimate interests.
Processing of Personal Data by us
a) Log files
Each time a user accesses our website and each time a file is retrieved, data about this process is temporarily processed in a log file. In detail, the following data is stored for each access/retrieval: a) Date and time of the retrieval (time stamp), as well as the IP address of the accessing device or server, b) request details and destination address (protocol version, HTTP method, referrer, User Agent string), c) name of the retrieved file and transferred data volume (requested URL incl. query string, size in bytes) and d) Message as to whether the retrieval was successful (HTTP status code).
On the basis of our legitimate interest in a secure website, we store this data to protect against attacks for up to 7 days beyond the time of your visit. This data is analyzed and required for legal and criminal prosecution in the event of attacks on communications technology. The data is deleted as soon as it is no longer required for the performance of tasks.
b) Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies:a) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and b) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
We think it’s important that you have full control over your privacy online and that is why we deliberately decided not to place cookies that are non-essential such as functional, performance or advertising cookies. As set out in the EU`s Privacy and Electronic Communications Directive (“PECD”), we don’t need to obtain consent when we don’t use them, and this is why we don’t need one of these annoying cookie pop ups.
c) Hosting
To provide our website, we use the services of WordPress by Automatic Inc who processes all data to be processed in connection with the operation of this website on our behalf. The legal basis is our legitimate interest.
d) Content Management System (CMS)
We use the Content Management System (CMS) of WordPress a service provided by Automattic Inc, to publish and maintain the created and edited content and texts on my website. This means that all content and texts submitted to my website is transferred to WordPress. The legal basis for this processing is our legitimate interest.
e) Contacting us
Personal Data is processed when you contact us. This may include your name and e-mail address, IP address and we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is your consent.
f) Comments and contributions in our blog
When users leave comments or other contributions, their IP addresses are stored for 7 days on the basis of our legitimate interests for 7 days. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Within the Blog you may be able to display certain profile information, share certain details, engage with others, exchange knowledge and insights, post and view relevant content. Content and data are publicly viewable. You have choices about the information on your comment. You don’t have to provide additional information on your comment; however, information helps you to get more from our Services. It’s your choice whether to include sensitive information on your comment and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be available. The legal basis for the storage is our legitimate interest and your consent.
g) Blog Notifications
If, you are giving your consent to receiving notifications per email, WordPress will use your e-mail address to notify you of comments replies and interactions with your comments on our blog. Within your WordPress account or the notification received you are able to unsubscribe from further notifications. The legal basis for the storage is our legitimate interest and your consent.
Your Rights and Privileges
a) Privacy rights
Under the GDPR, you can exercise the following rights:
• The right to access – You have the right to request copies of your Personal Data. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your Personal Data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your Personal Data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your Personal Data, under certain conditions.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you have any questions, please contact us.
b) Updating your information
If you believe that the information, we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.
c) Withdrawing your consent
You can withdraw consents you have given at any time by contacting us.
d) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection.
Validity and questions
This Privacy Policy was last updated on Thursday, March 23, 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.
Clan Mackenzie Initiative 