This privacy policy is intended for users of our website, digital applications, and digital platforms. It explains how we gather and utilise the personal data that we have about you, and provides information on how to exercise your legal rights.

In this document, ‘us’,‘we’ and ‘our’ refers to the website leandrogramani.org and the digital applications and digital platforms that may be made available through the website leandrogramani.org.

Personal data may be comprised of:

• Your name, email address, contact phone number, and date of birth, along with your residential address if you’ve requested us to dispatch something to your home

• Details of your debit or credit card

• Data about your devices, such as IP address

• Your browsing habits on our websites

• Information about the products or services you acquire

User data we process

If you sign up for an account on our website to comment on a post, participate in a contest, access one of products or services or receive chosen newsletters, you may need to give us your full name, email address, phone number, date of birth, and postal code. If you intend to interact in posts or conversations on our website, you will need to provide us with a username for commenting. If you are subscribing to one of our fee-based products or services, in addition to your name, email address, date of birth, and postal code. you will also need to provide your billing address and payment card details. This information may also be gathered if you attend one of our ticketed live, online or presential events. If you participate in one of our events virtually, we may share your name and contact information with the platform hosting the event.

If you acquire a product or service on our website, digital applications, digital platforms, or offered in collaboration with one of our associates, we may gather your name, email, contact number, address, MAC/IP address, purchase history and your preference for receiving marketing communications. We gather this data to execute your order, provide updates and maintain a record of your order, as well as to offer you support services and track warranties. Transactions are handled through a third party, hence we don’t have access to your financial specifics. We and our associates process your data as joint controllers under data protection legislation. This implies that we jointly decide the personal data that we gather and how we utilize it, and we are both accountable for this usage. At the time of your purchase, a privacy policy page from our partner(s) will be provided, if applicable.

If you reach out to our Customer Services or support team, we will require your name and contact details as well as comprehensive details of your inquiry.

We do not target our service to individuals under the age of 18, and we do not intentionally gather personal data about them.

Your data may be stored with a contracted associate of ours, which may involve transfer to the US or other countries. This will occur using approved UK Standard Contractual Clauses for data transfers or other similar safeguards that have been approved by the relevant authority.

You may be offered the chance to opt in for additional communications from us through emails or other services that may operate through your phone number, related to updates or events. We will process the data you provide us under consent.

We gather data about visitors to our website using technology such as cookies, device IDs, IP addresses and location data. This can include data about your location, the type of device you are using and your online browsing history.

About cookies

For virtually any contemporary website to function correctly, it needs to collect certain fundamental information on its users. To accomplish this, a site will generate files known as cookies – which are small text files – on its users’ computers, tablets or mobile devices. These cookies are engineered to allow the website to recognize its users on subsequent visits, or to authorize other designated websites to recognize these users for a specific purpose.

Cookies perform several different tasks which make your Internet experience much more seamless and interactive – like remembering your preferences on sites you visit frequently and your user ID and the contents of your shopping baskets, and to assist you in navigating between pages more efficiently. They also work to make sure you see online advertisements more pertinent to you and your interests. Some collected information is designed to identify browsing patterns and geographical locations related to you or to your browsing habits to enhance user experience.

Certain websites may also employ web beacons (also referred to as pixels or tags) to gather data, which are integrated into images. Web beacons only amass limited data, including a cookie number, a timestamp, and a record of the page where they are positioned. Websites may also feature web beacons placed by third-party advertisers. These beacons do not carry any personally identifiable data and are solely used to monitor the efficacy of a specific campaign (for instance by tallying the number of visitors).

Data gathered by cookies is now categorized as personal data.

How we employ cookies

We amass a variety of cookies from our users for several reasons, not least to monitor our own performance – but also to let us serve you content tailored to your own specifications, hopefully enhancing your overall experience of the website. Among other things, the cookies we use allow users to register to make comments, allow us to calculate how many visitors we have and how long they stay on our site.

We do our utmost to respect users’ privacy. We use cookies to monitor and enhance our services, but they may also allow us to sell advertising campaigns that are tailored to user interests and reading behaviour on our website, which may help keeps our content free to our readers. We sometimes include links on our site to goods and services offered by third parties and we may be paid some commission if you subsequently decide to make a purchase. Cookies may be used to track your visits to third-party sites to help ensure that we are paid the correct amounts. These commercial arrangements do not influence our other unrelated editorial contents in any way.

We believe that your experience of the site would be negatively impacted if you opted out of the cookies we use.

Existing types of cookie and the ones do we use

There are two types of cookie:

• Persistent cookies linger on a user’s device for a set duration of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

• Session cookies are temporary. They allow website operators to link the actions of a user during a browser session. A browser session commences when a user opens the browser window and concludes when the browser window is closed. Once you close the browser, all session cookies are erased.

Cookies, in general terms, serve four distinct purposes and can be classified as follows: ‘essential’ cookies, ‘performance’ cookies, ‘functionality’ cookies, and ‘marketing’ or ‘advertising’ cookies.

‘Essential’ cookies are crucial for navigating around a website and utilizing its features. Without them, you wouldn’t be able to access basic services like registration or shopping carts. These cookies do not collect information about you that could be used for marketing or remembering your internet journey.

We use ‘essential’ cookies by:

• Assigning unique identifiers to each unique visitor, enabling site numbers to be analysed.

• Enabling users to log in to our website as a registered user or subscriber.

‘Performance’ cookies gather data for statistical purposes on how visitors interact with a website. They don’t contain personal information such as names and email addresses and are used to enhance your user experience of a website.

Examples of how we use performance cookies:

• Collecting data about visits to the website, including numbers of visitors and visits, duration of time spent on the site, pages clicked on, or where visitors have come from.

• Comparing with other websites using data collected by industry-accepted measurement and research companies.

The information provided by performance cookies helps us understand how you use the website; for example, whether or not a user visited before, what you looked at or clicked on, and how you found us. We can then use this data to help improve our services. We generally use independent analytics companies to perform these services for us and when this is the case, these cookies may be set by a third-party company (third-party cookies).

If you have registered with the website, we can combine the data from the web analytics services and their cookies with the information you have supplied to us, so that we can make your experience more personal by recommending certain articles to you based on your reading behaviour or tailoring your emails with content you might find more interesting. We would only do this if you have given us permission to communicate with you. Sometimes the data used from the web analytics companies has been collected before you registered or signed in. In these cases, if we use this data to identify you, we use it only in accordance with our privacy policy.

‘Functionality’ cookies enable users to personalize their experience on a website: they can recall usernames, language settings, and regions, and can be utilized to offer more personalized services like local weather updates and traffic news.

Examples of how we use ‘functionality’ cookies:

• Retaining your user preferences on your account page.

• Recalling if you’ve visited the site before so that messages intended for first-time users are not shown to you.

‘Advertising’ cookies are employed to deliver advertisements that are more pertinent to you, but can also restrict the number of times you see an advertisement, and be used to gauge the effectiveness of an ad campaign by tracking users’ clicks. They can also provide security in transactions. They are typically placed by third-party advertising networks with a website operator’s permission, but can be placed by the operator themselves. They can recall that you have visited a website, and this information can be shared with other organizations, including other advertisers. They cannot identify who you are though, as the data collected is never linked to your profile.

Examples of how we use advertising cookies:

• Interest-based advertising (or online behavioural advertising) is where cookies are placed on your device by our third party service providers which recall your web browsing activity and group together your interests in order to provide you with targeted advertisements which are more relevant to you when you on or from our website. Your previous web browsing activity can also be used to infer things about you, such as your demographics (age, gender etc). This information may also be used to make the advertising on or from our site more relevant to you.

• ‘Retargeting’ is a form of interest-based advertising that enables our advertising partners to show you advertisements selected based on your online browsing activity away from the website. This allows companies to advertise to people who previously visited their website or interacted with ads or other contents related to or from their websites on the internet. These cookies will usually be placed on your device by third-party advertising networks. The main third party networks we work with are Meta and Google Ads.

• Social media. Occasionally we advertise our products and services to our users who are on social media. This could be to promote our subscriptions offers or events. We use cookies to assist with this process, and the social media operator (Facebook for example) can recognize customers who are on their platform and serve them advertisements on our behalf.

Without these cookies, online advertisements you encounter will be less relevant to you and your interests, which tend to render a poorer user experience.

How to regulate cookies

You should be cognizant that any preferences will be lost if you eliminate all cookies and numerous websites will not function correctly or you will lose some functionality. We do not advocate disabling cookies when using our website for these reasons.

Most browsers accept cookies by default, but you can modify the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. Generally, you have the option to view what cookies you have and delete them individually, block third-party cookies or cookies from specific sites, accept all cookies, to be notified when a cookie is issued or reject all cookies. Visit the ‘options’ or ‘preferences’ menu on your browser to alter settings, and check the following links for more browser-specific information:

Internet Explorer

Firefox

Chrome

Safari for macs

Safari for iOS

It is feasible to opt out of having your anonymised browsing activity within websites recorded by performance cookies. Please note that if you wish to opt out from receiving targeted advertising, this does not imply that you will receive less advertising when you use our website. This simply means that the advertising you see will not be as tailored to you.

You can modify your consents to the use of cookies at any time by clicking on http://www.youronlinechoices.com/uk/your-ad-choices. This will provide you with a list of all cookies that are currently set on your device and how to opt out of each of them. Please note that this list will contain more networks than just found on our site. If you choose to decline our cookies, we cannot guarantee that your experience will be as satisfying as it would otherwise be. For instance, the site may not be able to recognise your user ID, meaning that you won’t be able to interact or leave comments.

Supplementary data gathering and usage

At times, we may acquire extra data about you from third parties. When this occurs, those parties will be enumerated here. The information these corporations might possess about you is gathered from publicly accessible records, such as the electoral roll, or from other sources where you have consented for your data to be shared with third parties. We may cross-check our database of registered users against the data they hold on their systems to identify any matched individuals. If there is a match, we can gather and store some of this supplementary data (which may include statements about your lifestyle and interests) in our database and use it to further refine our understanding of the types of products and services you might be interested in. We may also correlate your cookie data with this third-party data, and amalgamate this data into interest-based segments or profiles which we use to develop our products, or serve you more relevant advertising. At times, we share these segments with other publishers so they can display advertising on their websites. We can also combine these segments with those from other publishers so that advertisements can be displayed across multiple websites to readers while limiting the number of times you see the ads. With your consent, we may share your IP address and first-party cookie with Experian who will use it to carry out data profiling by associating your IP address and first-party cookie with their own IP address database, and subsequently, to one or more of the “predictive models” they have created. Experian’s predictive models are created using data from various data sources (including public data sources) and are used to attempt to predict behaviour and preferences (e.g. how likely you are to buy a holiday online or take a particular type of holiday) or likely circumstances (e.g. Experian’s model might predict you are a city dweller and therefore less likely to be interested in gardening). Experian will not share the details we provide to them about you with any third party but will use and store it primarily to help:

• us better comprehend the likely characteristics of visitors to our website(s);

• us enhance the relevancy and appropriateness of the advertisements we display to you when you visit our website(s); and

• Experian to associate identifiers with the identical IP address for the purpose of implementing their predictive models

To comprehend more about the usage of your data by Experian, including which lawful basis Experian depends on to process your personal data and how to exercise your data protection rights in relation to their use of your data (including how to opt-out), please navigate to the Experian website at https://www.experian.co.uk/marketing-services/consumer-information-portal

We can also access data from social media activity such as when you ‘like’ the website, share content or follow us on social media platforms. When you log in to the website using social media you grant permission to the social network to share some of your details with us. Depending on the network this will include basic account information such as name, email address, date of birth and any other details you choose to share according to your specific social media account settings. We may also gather information about third-party products and services which you purchase after visiting the website. For instance, when you use a voucher code or click on a link to an advertiser’s site.

Purposes for collected data use

• Confirming your identity (for example when you return to the website and have already logged in).

• Customising the advertising you see on or from the website so that it is more relevant to you using, for example, cookies, as previously explained in this document.

• Enhancing the design and style of the website.

• Notifying you about products, services or promotional offers that you might find interesting if you have chosen to receive these type of communications.

• Sending you service messages about your products or services or account registration, for example if you have clicked a password reset link. This could be, for example, by email, overlay on the website or push notification.

• Handling, and responding to you about, a comment you have submitted for or on our message boards, blogs and other such user-generated content facilities.

• Enabling you to share our content with others using social media or email.

• Engaging (and customising such engagement) with you through our bulletins, posts, newsletters and communications you have agreed to receive.

• Overseeing contests and notifying you if you have been victorious in any contests or promotions.

• Assembling customer feedback.

• Undertaking market analysis.

• Dispatching a product to your residential address.

• Providing you access to a product or service.

• Addressing any inquiry or grievance you submit to our customer services team. Only provide sensitive data (such as information about your health, race or religion) if you are comfortable consenting to our use.

• Transmitting you push notifications from our applications.

• Ensuring that we are remunerated the correct amount of commission by our advertising partners.

We also record and utilise information about any service errors or interruptions that you have encountered in order to aid us in creating fixes and to make technical enhancements to our website.

How we may reach out to you

Periodically we may contact you by e-mail, push notification or messaging services that operate through your phone number, to provide you service information. For instance: if a subscription is nearing its end, or your payment method has expired.

If we have your consent we may also transmit you bulletins or e-mails or newsletters or messages using messaging services that operate through your phone number, about our events, subscription benefits or offers. Occasionally we may inquire if you would like to participate in market research, or respond to you if you have lodged a complaint or have logged a query.

Legal basis for processing personal data

1. Consent.

We will only utilise your personal data for promotional and marketing activities, tailoring of content and services, analytical objectives (such as, comprehending who our users are and their browsing habits on our websites and platforms) and to monitor eCommerce and other online purchases if we have your explicit consent to do so. This includes the use of data provided by you and our partners for profiling purposes in order to generate revenue from you so we can enhance our products and services.

If you have granted us consent to send you specific newsletters, you can opt out from these at any time by clicking unsubscribe at the bottom of each email, or by logging into your account and managing your email preferences.

2. Legitimate interests.

The legitimate interest pursued by us to analyse our website traffic in order to maintain the service, for example monitoring successful page loads or error messages.

3. Performance of a contract.

When you purchase a subscription or another product or service from us, we will need to process your details in order to supply the item to you (for example, to deliver a product to your home, we would need to use your name and address).

How to access and update your personal information

At any time you can request access to a copy of the personal information we may hold about you and to ask for that information to be deleted or updated by writing to [email protected]

Data storage duration and processing

We will retain your information only for as long as it is relevant and useful for the purpose for which it was originally collected.

If your account appears to have not been used for 12 months, we may attempt to contact you to check whether it is still in use and/or we may delete it. Please note that any comments or interactions associated with your account may also be deleted.

If you do not read the newsletters that you have subscribed to, we may suppress your name from the relevant list after 6 months.

If you have bought a subscription, product or service, we will preserve your data for at least 12 months following the conclusion of your purchase in case there are any unresolved billing or other customer service issues.  A record of a customer service inquiry is preserved for at least three years from the date it was submitted to us. We preserve cookie data and corresponding third-party data for 18 months from when it was gathered from your device. We may need to preserve your data for a longer period if there is a legal claim or if we are mandated to do so by any regulation.

Who will we disclose your personal information to

We may reveal your personal information to our affiliated companies or partners, as long as they pledge to adhere to the same privacy standards of this current privacy policy. Advertisers and advertising networks occasionally require data to select and serve relevant advertisements to you and others. We may provide them with aggregate cookie information about our users with certain attributes (for example, we may inform them that 300 women aged under 50 have clicked on their advertisement on any given day). We may also use such aggregate information to assist advertisers in reaching the kind of audience they wish to target (for example, men in the UK who are interested in boats). We share cookie data with other publishers via secure data management platforms when advertising campaigns are served across multiple websites.  These publisher partners are not able to access this data themselves, only serve the advertisements across their own websites to readers whose cookie data form part of the selected advertising segments.

We reserve the right to disclose your personal information to comply with applicable laws and government or regulatory bodies’ lawful requests for information.

Your personal details may be shared with third-party organisations we have contracted to provide services to us which include processing data.  For example, to send you the emails you have signed up for. Only companies who can provide adequate safeguards will be used to ensure your data is stored and handled securely.  We may also have to release information because of a legal requirement on us or pursuant to a court order.

We may relocate, vend or delegate any of the details outlined in this Privacy Policy to third parties as a consequence of a sale, amalgamation, consolidation, shift of control, transfer of assets or reorganisation of our enterprise.

Utilising children’s personal data

We do not target our services to children under the age of 13.  We do not knowingly permit children under 18 to register an account with us.

Overseas and international data transmission

As you are aware, the internet does not acknowledge national boundaries. Services on the web are accessible globally so the collection and transmission of personal data is not always restricted to one country. You should be cognizant that by using our website and platforms and those of our partners or any website we link through to, your personal data may be processed in or transferred to other countries, like the USA or Brazil for instance, and you consent to your personal data being transferred or processed in this manner.

Your personal data will only be stored or transferred nationally or internationally using Standard Contractual Clauses, or other safeguards that have been approved by the relevant respective regulatory body.

Your rights

Right of access – you possess the right to request a copy of the data that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – you can request for the data we hold about you to be erased from our records.

Right to restriction of processing – you can request for us to restrict the way we process your data.

Right of portability – you possess the right to have the data we hold about you transferred to another organisation.

Right to object – you possess the right to object to our processing your data where we are relying on a legitimate interest in order to process it.

Right to withdraw your consent – you possess the right to withdraw your consent at any time.

Please note that these rights are not absolute and certain exemptions may apply as long as they are lawful.

Exercising your rights, asking questions and raising concerns:

Please submit any requests to [email protected]