Privacy Policy
- Created June 2020.
- Reviewed October 2023, September 2024. Ratified 5 November 2024.
Fighting Words NI is a charity and company registered at the following address:
Connswater Shopping Centre
Bloomfield Avenue
Belfast
BT5 5LP
Charity Registration No: NIC105751
Company No: NI638582
At Fighting Words NI, we are committed to maintaining the trust and confidence of visitors to our website, subscribers to our newsletter, people who contact us, and those who participate in our activities.
Here you’ll find information on how we treat data that we collect from website visitors, newsletter subscribers, and those who are interested in volunteering.
Visitors to our Website
When someone visits www.fightingwords.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is processed in a way that does not identify users. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Read Google Analytics Data Collection policy (See Appendix A below)
Newsletter Sign-Up
As part of the registration process for our e-newsletter, we will collect two pieces of personal information (your email address and name). We use that information to:
- Tell you about what's happening at Fighting Words NI, and occasionally news from other organisations that we feel is of interest;
- Contact you if we need to obtain or provide additional information;
- To check our records are right; and to
- Check in every now and then that you’re happy and satisfied receiving our newsletters.
Please contact us any time via this contact form.
Originally written: 1 November 2021
Updated: 10 October 2023, 18 July 2024, September 2024
Date of next Review: October 2025, Board of Trustees meeting
5.3. Log Data monitoring: we may collect log data whenever you access our tool. This data could include things like an IP address, browser type, and version, the pages you visit on MailerLite, and other user statistics. When you access MailerLite with a mobile device, log data may include the type of device, your mobile unique ID, the IP address of your device, mobile operating system, and other mobile statistics.
5.4. Third-party services: we may use third-party services, such as Google Analytics and Facebook, that collect and analyze log data to help us improve MailerLite, and occasionally to use for targeted online advertising. Our third-party partners may use cookies or other tracking technologies to provide you advertising on other sites based on your browsing activities and interests. You can find more information about these practices, including how to opt out of receiving targeted advertising here: http://www.aboutads.info/choices/.
5.5. Based on the requirements of the California Online Privacy Protection Act, MailerLite declares that it does not correspond to Do Not Track browser signals.
6. Transferring to third-party companies
6.1. We will never sell, rent, or lease your Personal Data to a third party, but we may share collected information for the purposes described in this Privacy Policy with third parties, including group companies, that help MailerLite provide, improve, promote or support Services, that help with our business operations and assist in the delivery of our Services, or who perform services for us, in order to prevent damage to our property or for safety reasons, for example, payment processors, hosting services, analytics, content delivery services, advertising partners, etc., in a manner that is consistent with this Privacy Policy. We may also share information with third parties if required to do so by law or if you violate our TOU.
6.2. We may disclose Non-Personal Data for any purpose because this information cannot be used to identify you or another person.
7. Email communications & opting out
7.1. From time to time you may receive emails related to your use of MailerLite. Based on the Personal Data that you provide us, we may communicate with you in response to your inquiries to provide the Services you request and to manage your account. If we have your consent, we may also use your Personal Data to send you updates and other promotional communications. Every email will contain a link to be able to opt-out of receiving it. We may still send important messages regarding administrative matters, updates, disputes, and customer service issues that are required to provide the Services.
7.2. If a Subscriber no longer wants to be contacted by one of our Customers, he can unsubscribe directly from that Customers’ newsletter or contact the Customer directly to update or delete the data. If a Subscriber contacts us, we will refer him to that Customer. We will retain personal information we Process on behalf of our Customers only for as long as needed to provide our Services or to comply with our obligations.
8. Safety of your information
8.1. MailerLite takes reasonable precautions, technical and organizational security measures to ensure a level of security appropriate to the risk, follows industry best practices in order to protect your Personal Data from any unauthorized or unlawful breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to Personal Data and to preserve the security and confidentiality of the data. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such precautions. By using our Service, you acknowledge that you understand and agree to assume these risks.
8.2. The customer is responsible for reviewing the information made available by MailerLite relating to its data security and making an independent determination as to whether the Services meet Customer’s requirements and legal obligations under Data Protection Laws. Also, Customer is responsible for its secure use of the Services, including securing its account authentication credentials, protecting the security of Personal Data when in transit to and from the Services and taking any appropriate steps to securely encrypt or backup any Personal Data uploaded to the Services.
9. Protecting Subscriber’s lists and data
9.1. We reserve the right to monitor your lists, content and response data from time to time to make sure they comply with our TOU, we will never share, sell or rent your customer data to anyone for any reason.
9.2. Our data storage center is in the European Union and has information storage security certificate (ISO 27001) so you can rest assured that your Subscribers data is safe with us.
10. Links to other websites
As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Service. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.
11. Data Processing Addendum
We created our Data Processing Addendum to cover the GDPR requirements as they relate to email marketing and we encourage all our Customers to review it here.
12. Age of consent
By using the Service, you represent that you are at least 16 years of age.
13. California Consumer Privacy Act
13.1. According to The California Consumer Privacy Act (“CCPA”) residents of California, United States have specific rights regarding their Personal Data. California consumers have the right to 1) request that businesses disclose information about their collection and use of Personal Data over the past year; 2) ask such businesses to delete Personal Data; 3) opt-out of the sale of their Personal Data.
13.2. MailerLite in terms of CCPA acts as a service provider and we process Personal Data on our Clients behalf. Please direct any requests for access or deletion of your Personal Data to our Clients with whom you have a direct relationship.
14. Merger or acquisition
In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Data may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to Process your Personal Data as set forth in this Privacy Policy.
15. MailerLite as a Controller
MailerLite acts as a Controller of Personal Data of its employees, contractors, candidates, affiliates and other third parties that are not considered as a Customer. MailerLite undertakes to comply with legal requirements when processing Personal Data as a Controller and implements appropriate technical and organizational measures to ensure a level of security of Personal Data as required under GDPR and applicable Data Protection Laws.
16. Changes
MailerLite reserves the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy, we will post these changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. All changes are effective immediately upon posting and we suggest that you check this Privacy Policy periodically if you are concerned about how your information is used.
17. Contacting MailerLite
If you:
would like to request access to the information we hold about you, correct, modify, delete or update Personal Data that you have provided to us, or have any questions regarding this Privacy Policy or the practices of this site, wish to withdraw your consent for the continued collection, would like to object to your Personal Data being used, or have any additional questions:
4. Purposes of Processing
4.1. MailerLite uses collected information for the operation of the Services, to maintain the quality of the Service, to provide general statistics regarding use of the Service, to promote and analyze the Services, to provide customer support and send information about the Services, to protect the rights and safety of Customers, Subscribers, third-parties and our own, to send customized informational or promotional content and provide suggestions according to marketing preferences, to ensure observance of our TOU and meet the legal requirements, to verify identity and provided information, manage payments, to understand demographics, Customer interests and needs, and other trends among users, and for other business purposes.
4.2. We may combine Personal Data with other information we Process to customize informational content and enhance our ability to provide Services according to marketing preferences, restrictions or for advertising, targeting purposes, personalization of ads, or to develop and provide you with more relevant products and features in accordance with this Privacy Policy.
5. How we collect your information
5.1. Data provided by our Customers: Customers may import into the Services Personal Data they have collected from their Subscribers or other individuals. We have no direct relationship with Customers’ Subscribers or any individuals other than our Customers. Our Processing of Personal Data is based on the data subject freely given consent and Customers are responsible for making sure they have the necessary permissions for us to Process Personal Data about Subscribers or other individuals.
5.2. Tracking technologies: in connection with the performance of the Services, MailerLite uses:
Cookies: cookies are tiny files of data that a website transfers to your computer's hard disk for record-keeping purposes. Most web browsers are set to accept cookies, but you can change this in your browser settings. However, if you do not accept cookies, you may not be able to use all of MailerLite’s functionality. We use cookies to improve your Mailerlite experience and by collecting this data, we can store information so that you don’t have to re-enter it every time you visit MailerLite. We also use it to monitor visitor metrics to MailerLite such as page views, time on site, number of visitors, etc. Web beacons: we include single-pixel gifs (web beacons) in emails we send, which allow us to collect information about when you open the email and your IP address, your browser or email client type, and other similar details. We use the data from those web beacons to create reports about how your email campaign performed and what actions your Subscribers took, to capture the time spent on the Services, pages visited and email campaign performance. Unique identifiers and similar tracking technologies: we may use other tracking technologies to administer the Services, track your movements around the Services, analyze trends, track behavior, serve targeted advertisements and gather demographic information, to measure the performance of our email campaigns and to improve our features for specific segments of Customers.
3.1.1. At any time, you may log in and change this information, or remove it. You may decline to provide Personal Data to the Services, however, some of the Personal Data we ask you to provide, for example, the email address is mandatory for a Service. If you decline to provide it, we may not be able to provide that service to you.
3.1.2. Please note, MailerLite does not process or store your credit card information. Once you make a payment, your credit card information is transferred to our third-party payment processor Braintree. Please find their Privacy statement here.
3.1.3. If, being a Shopify user, you install MailerLite Shopify app through Shopify App Store, Shopify will bill you for our Services. More information about Personal Data collected by Shopify can be found in Shopify’s Privacy Policy here.
3.1.4. Please be informed that for communication via email and live chat, MailerLite uses third-party customer support platforms. When communication goes through our Contact Us form or email, your information is transferred to HelpScout. When communication is through live chat, your information is transferred to Intercom. If you reach out to us when using the new version of MailerLite, regardless of the method, your information will be transferred to HelpScout. You may find HelpScout’s privacy policy here and Intercom’s here.
3.1.5. MailerLite utilizes OpenAI’s GPT technology, providing features such as an AI-powered writing assistant and AI-powered subject line generator. By using these features, you agree that your input, which may contain personal information, is sent to OpenAI's API for processing in accordance with OpenAI's Terms of Service, Privacy Policy and API Data Usage Policy. MailerLite is not responsible for the data handling practices or policies of OpenAI or any third-party services used by OpenAI.
3.2. Non-Personal Data:
The browser and device information: location, device type, model, number, type of browser or operating system, the time and date of access, screen resolution, plug-ins, add-ons and the version of the Services you are using, and other information that does not personally identify you. Information from your use of the Services and information from other sources: we may receive information about how and when you use the Services, or other types of files associated with your account, and link it to other information we collect about you. Also, we may obtain information about you or your Subscribers from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners. This information may include, for example, time, date, browser used, demographic information, device information (such as device type, model, number, type of browser or operating system), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links), actions you have taken, anonymous usage data, referring/exit pages and URLs, preferences you submit and preferences that are generated based on the data you submit and the number of clicks.
See a full list of the default events and user properties collected by Google Analytics.
Analytics also collects enhanced measurement events (when enabled) from web data streams and in-app purchases from app data streams.
Identifiers for websites
Google Analytics stores a client ID in a first-party cookie named _ga to distinguish unique users and their sessions on your website. Analytics doesn't store the client ID when analytics storage is disabled through Consent Mode.
Identifiers for mobile devices
The Google Analytics for Firebase SDK automatically generates and assigns an app-instance identifier to each instance of your app. Analytics uses the ID to identify unique installations of your app and compute user metrics. Learn more about the app-instance ID.
By default, the SDK collects identifiers for mobile devices (for example, Android Advertising ID and Advertising Identifier for iOS) and uses technologies similar to cookies.
On iOS, the SDK collects the Advertising Identifier (IDFA) if it is available. For the IDFA to be available, a developer has to link in the AdSupport.framework library and on iOS14.5+ receive user authorization from the App Tracking Transparency framework. If the Advertising Identifier is unavailable, the SDK collects the Vendor Identifier. If the Advertising Identifier becomes available after the Vendor Identifier was reported, the SDK stops collecting the Vendor Identifier.
On Android, the SDK collects the Advertising ID by default. For the Advertising ID to be available, a developer has to include the com.google.android.gms.permission.AD_ID permission in the SDK's manifest file. To collect the Advertising ID, the SDK includes the com.google.android.gms.permission.AD_ID permission in the SDK's manifest, which automatically merges into the app manifest by the Android build tools. The Advertising ID is removed when a user opts out of personalization using advertising ID in Android Settings. Any attempts to access the identifier will receive a string of zeros instead of the identifier. To learn more about the AD_ID permission declaration, see Advertising ID in the Play Console Help.
Appendix B: MailerLite Privacy Policy
Privacy Policy
At MailerLite, protecting your privacy and the privacy of anyone receiving your email is very important to us. The purpose of this Privacy Policy is to make MailerLite safe and appropriate for everyone. Our Privacy Policy applies to your use of MailerLite’s Services and describes the kind of information we process, how it is processed and why.
As used in these Terms, "MailerLite" means:
(a) MailerLite Limited, an Irish registered company at Ground Floor, 71 Lower Baggot Street, Dublin 2, D02 P593, Ireland, if the Customer's billing address on the applicable Order Form is located in the EEA, UK or Switzerland; or
(b) MailerLite, Inc., a Delaware corporation at 548 Market St, PMB 98174, San Francisco, CA 94104-5401, United States, if the Customer's billing address on the applicable Order Form is located anywhere else in the world.
MailerLite provides email marketing and automation software as a service. We process Personal Data as a Processor on behalf of the Customer.
1. Definitions
1.1. "Controller" means an entity that determines the purposes and means of the Processing of Personal Data.
1.2. "Customer" means a person or entity that is registered with MailerLite to use the Services.
1.3. "Data Protection Laws" means all data protection and privacy laws and regulations of the EU, EEA, and their member states, Switzerland and the United Kingdom, applicable to the Processing of Personal Data.
1.4. "GDPR" means (a) the Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), and (b) the United Kingdom General Data Protection Regulation.
1.5. "Personal Data" means any information relating to an identified or identifiable natural person.
1.6. "Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction. "Process", "Processes" and "Processed" shall be interpreted accordingly.
1.7. "Processor" means a natural or legal person, public authority, agency, or any other body which Processes Personal Data on behalf of the Controller.
1.8. "Services" means any product or service provided by MailerLite pursuant to MailerLite’s Terms of Use ("TOU").
1.9. “Subscriber” means a person Customer contacts through our Services.
1.10. “We”, “us”, and “our” refer to the MailerLite.
1.11. "You," "your," and "yours" refer to the user.
2. Data Processing
2.1. Consent: by accessing our Services, you accept our Privacy Policy and TOU, and you consent to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy. Each time you visit our website or use the mobile app or the Service, and any time you voluntarily provide us with information, you agree that you are consenting to our collection, use, and disclosure of the information that you provide, and you are consenting to receive emails or otherwise be contacted, as described in this Privacy Policy. Whether or not you register or create an account with us, this Privacy Policy applies to all users of the website, mobile app, and Services.
2.2. Performance of a contract: by utilizing our Services or accessing our platform, you expressly acknowledge our Processing of your Personal Data in compliance with applicable Data Protection Laws. The Processing of your Personal Data is grounded on the legal basis of contract performance between you and MailerLite. We collect and process your Personal Data to deliver the requested Services, meet our contractual obligations, and ensure the seamless functioning of our platform. Specifically, this includes providing you with access to the website, mobile app, and Services.
3. What information we Process
MailerLite collects both “Personal Data” and “Non-Personal Data” about you and will Process this data for the duration of the Services, as described in the TOU:
3.1. Personal Data:
Customers' information: identification and contact data (name, contact details, username); billing information (billing address, payment information); organization information (name, address, geographic location, area of responsibility, VAT code), IP addresses, browsing activity, web server logs. Subscribers' information: email address and any other additional information that Customer provides to MailerLite.
We hold all of your personal information securely. We don't rent or trade email lists with other organisations and businesses.
We use a third-party provider, MailerLite, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see https://www.mailerlite.com/legal/privacy-policy. (See (Appendix B below).
MailerLite is subject to EU Data Protection Law. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our newsletter emails or by emailing digitalstoryteller@fightingwords.co.uk.
People who email us
Our email provider is Outlook (via Microsoft Office 365). For more information, you can read Microsoft’s privacy notice.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
Links to Other Websites
This privacy notice does not cover any links within this site guiding you to other websites, including partners, funders, or other charities. Those sites are not governed by this Privacy Notice, and if you have questions about how a site uses your information, you’ll need to check each organisation’s own privacy statement.
Access to Your Personal Information
You are entitled to access the personal information that we hold. Email your request to the data protection officer, Aoife Osborne, at volunteer@fightingwords.co.uk
Changes to this Privacy Notice
We keep our privacy notice under regular review. This privacy notice was last updated September 2024.
WEBSITE COOKIES POLICY
We use a system of classifying the different types of cookies which we use on the website, or which may be used by third parties through our website. The classification was developed by the International Chamber of Commerce UK and explains more about which cookies we use, why we use them, and the functionality you will lose if you decide you don't want to have them on your device. When you visit our website, we will ask for your consent to cookies. You can withdraw consent at any time by clicking on the “Privacy Notice” tab.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device.
How long are cookies stored for?
Persistent cookies - These remain on a user's device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies - These allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookies do many different jobs, such as letting you navigate between pages efficiently and remembering your preferences, and they generally improve the user experience.
You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.
Cookies used on our website
A list of all the cookies used on our website by category is set out below.
Strictly necessary cookies - These enable services you have specifically asked for. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
Performance cookies - These collect anonymous information on the pages visited. By using the website, you agree that we can place these types of cookies on your device. These cookies collect information about how visitors use the website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the website works.
Functionality cookies - These remember choices you make to improve your experience. By using the website, you agree that we can place these types of cookies on your device. These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Third-party cookies - These allow third parties to track the success of their application or customise the application for you. Because of how cookies work we cannot access these cookies, nor can the third parties access the data in cookies used on our site. For example, if you choose to ‘share’ content through Twitter or other social networks you might be sent cookies from those websites. We don't control the setting of these cookies, so please check those websites for more information about their cookies and how to manage them.
YouTube - We may embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. Read more at YouTube’s embedding videos information page.
Appendix A: Google Analytics Data Collection Policy
[GA4] Data collection
Understand what Analytics collects through the default implementation
Google Analytics collects the following information through the default implementation:
Number of users Session statistics Approximate geolocation Browser and device information