Last updated: [LAUNCH DATE]
This policy explains what we do with your personal data when you read standpointmag.co.uk, sign up to our newsletter, contact us, or subscribe.
We have tried to write it in plain English. If anything is unclear, ask us at hello@standpointmag.co.uk.
1. Who we are
Briarwood International LLC is the data controller for the personal data described in this policy. That means we decide why and how it is processed, and we are responsible for it.
| Company | Briarwood International LLC, trading as Standpoint |
| Formed under | The laws of Belize |
| Registration number | 000055766 |
| Registered office | 3301 Chetumal Street, Belize City, Belize |
| hello@standpointmag.co.uk |
Our UK representative
We are established outside the United Kingdom, but we offer services to people in the UK. The UK General Data Protection Regulation therefore applies to us, and under Article 27 we have appointed a representative in the United Kingdom.
If you are in the UK, you may contact our representative instead of us, on any matter relating to your personal data:
UK representative: hello@standpointmag.co.uk
Contacting the representative is not a substitute for your right to complain to the Information Commissioner’s Office — see clause 10.
We have not appointed a Data Protection Officer, as we are not required to. Data protection enquiries go to hello@standpointmag.co.uk, marked “Data protection”.
2. The law we work under
Because we offer services to readers in the United Kingdom, we process personal data in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR). These apply to us under Article 3(2) UK GDPR, which extends to controllers outside the UK who offer services to, or monitor the behaviour of, people in the UK.
Where readers are in the European Economic Area, the EU General Data Protection Regulation applies on the same basis.
We also comply with the data protection law of Belize as it applies to us.
We have chosen to apply UK GDPR standards to all readers, wherever they are. It is the highest standard that applies to any part of our readership, and applying one standard is simpler and better than applying several.
3. What we collect
3.1 Information you give us
When you subscribe to our newsletter: your email address, and — if you choose to give them — your first name, last name and country. We also record the date and time you signed up, the page you signed up from, and the date and time you confirmed your subscription.
When you contact us: your name, your email address, and whatever you put in your message. If you send us a pitch, that includes anything in the pitch and any attachments.
When you comment, if comments are enabled: your display name, your email address, your comment, and your IP address.
When you take out a paid subscription, once paid subscriptions launch: your name, billing address, email address, and a record of what you bought and when. Your card details are handled by our payment provider and are never seen or stored by us.
3.2 Information we collect automatically
Technical data. Your IP address, browser type and version, operating system, device type, screen size, and the pages you visit, in what order, and for how long. Some of this is in our server logs by necessity; some comes from analytics cookies, and is only collected where you have consented.
Cookie data. See our Cookie Policy for the detail.
3.3 Information from other sources
Mailchimp, our email platform, tells us whether you opened an email and whether you clicked a link in it. We use this to see which pieces readers actually read, and to stop sending to addresses that have gone dead.
Analytics, where you have consented, tells us about aggregate traffic patterns.
We do not buy mailing lists, and we do not enrich your data by matching it against third-party sources.
3.4 Special category data
We do not seek to collect special category data — information about your health, race, ethnicity, political opinions, religious beliefs, trade union membership, sex life or sexual orientation.
We are aware that subscribing to a political and cultural magazine could, in some circumstances, be taken to reveal something about a reader’s political opinions. We do not treat it that way, we do not profile readers on that basis, and we do not share subscriber lists with political organisations or anyone else.
If you volunteer special category information in a message to us — in a pitch, say, or a complaint — we process it only so far as necessary to deal with your message, on the basis that you have manifestly made it public or have given us your explicit consent by sending it.
4. Why we process it, and our lawful basis
| What we do | Data used | Lawful basis |
|---|---|---|
| Send you our newsletter | Email, name, engagement data | Consent (Article 6(1)(a)) — you opted in and confirmed, and you can withdraw at any time |
| Reply to your message or pitch | Name, email, message content | Legitimate interests (Article 6(1)(f)) — we cannot answer you without it |
| Run and secure the Site | Technical data, server logs | Legitimate interests — keeping the Site up, available and free from abuse |
| Understand how the Site is used | Analytics data | Consent for the cookies; legitimate interests for the analysis |
| Publish and moderate comments | Display name, comment, IP | Legitimate interests — running a comment section and dealing with abuse in it |
| Supply a paid subscription | Name, email, billing and order data | Performance of a contract (Article 6(1)(b)) |
| Keep accounting and tax records | Transaction data | Legal obligation (Article 6(1)(c)) |
| Deal with complaints, corrections and legal claims | Whatever is relevant | Legitimate interests — defending our position and correcting the record |
| Tell subscribers about our own similar products | Legitimate interests, within the soft opt-in at regulation 22(3) PECR, with an unsubscribe link every time |
Where we rely on legitimate interests, we have balanced our interest against your rights and concluded that the processing is proportionate and would not surprise you. You can ask us for our assessment, and you can object — see clause 10.
5. Marketing
We send marketing email only where you have opted in, or where you have bought something from us and we are sending you information about our own similar offerings under the soft opt-in.
We use double opt-in. When you sign up we send you a confirmation email, and you are not added to the list until you click the link in it. This protects you from being signed up by someone else, and it is how we evidence your consent.
Every email we send carries a one-click unsubscribe link. You can also email hello@standpointmag.co.uk and we will remove you. Unsubscribing takes effect immediately; if a campaign is already in flight you may receive one more.
We do not sell, rent or trade your email address. We do not share it with other publishers, advertisers, or political organisations.
6. Who we share it with
We share personal data with the following categories of recipient, and no others.
Service providers acting on our instructions. Each is bound by a written contract that meets the requirements of Article 28 UK GDPR, and none may use your data for its own purposes.
| Provider | What it does | Where |
|---|---|---|
| Intuit Mailchimp | Email list management and delivery | United States |
| [HOSTING PROVIDER] | Website hosting and server logs | [LOCATION] |
| [ANALYTICS PROVIDER] | Website analytics | [LOCATION] |
| [PAYMENT PROVIDER] | Payment processing (when paid subscriptions launch) | [LOCATION] |
Professional advisers — accountants, auditors and lawyers — where they need it to advise us.
Regulators and law enforcement, where we are legally required to disclose, or where disclosure is necessary to establish, exercise or defend legal claims.
A purchaser or successor, if the business or its assets are sold or reorganised. Any purchaser would be bound by this policy in respect of data acquired.
We do not share your personal data with advertisers.
7. Where your data goes
We are established in Belize. Our providers are in several countries, chiefly the United States. Your data will therefore be processed outside the country you live in.
Belize is not the subject of UK or EU adequacy regulations. Where personal data of readers in the UK or EEA is transferred to us or to our providers, we rely on the appropriate safeguards permitted by law, which for UK transfers means the International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses, supported by a transfer risk assessment. Where a provider is certified under the UK Extension to the EU–US Data Privacy Framework, we may rely on that instead — Mailchimp is operated by Intuit Inc., which participates in the Framework.
Wherever your data is processed, we apply the standards set out in this policy, and your rights under clause 10 are exercisable against us in full regardless of where processing takes place.
You can ask us for details of the mechanism applying to any particular transfer at hello@standpointmag.co.uk, or through our UK representative.
8. How long we keep it
| Data | Retention period |
|---|---|
| Newsletter subscriber data | Until you unsubscribe, then up to 12 months on a suppression list so we do not re-add you by mistake |
| Unconfirmed sign-ups (double opt-in not completed) | 30 days, then deleted |
| Correspondence and enquiries | 24 months from our last exchange |
| Pitches and unsolicited submissions | 12 months, unless we commission the piece |
| Comments | For as long as the article is published, or until you ask us to remove them |
| Paid subscription and transaction records | 7 years from the end of the relevant financial year |
| Complaints, corrections and legal correspondence | 6 years from resolution |
| Server logs | 90 days |
| Analytics data | 14 months |
Where we no longer need personal data, we delete it or anonymise it so that it can no longer be linked to you.
9. Security
We take appropriate technical and organisational measures to protect personal data, including encryption in transit (HTTPS across the whole Site), access controls, multi-factor authentication on the accounts that hold subscriber data, and keeping the number of people with access to a minimum.
No transmission over the internet is completely secure. We cannot guarantee the security of data sent to us, and any transmission is at your own risk.
If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner’s Office within 72 hours of becoming aware of it, and we will tell you directly where the risk to you is high.
10. Your rights
You have the following rights in relation to your personal data.
Access. You can ask for a copy of the personal data we hold about you, and information about how we use it.
Rectification. You can ask us to correct data that is inaccurate, or to complete data that is incomplete.
Erasure. You can ask us to delete your personal data. This right is not absolute — it does not apply where we need the data to comply with a legal obligation, or to establish, exercise or defend legal claims.
Restriction. You can ask us to suspend processing, for instance while we check the accuracy of data you have challenged.
Portability. Where we process data by automated means on the basis of your consent or a contract, you can ask us to provide it in a structured, commonly used, machine-readable format, or to transmit it to another controller.
Objection. You can object to processing based on legitimate interests. You can object to direct marketing at any time, and we will stop — there is no balancing test and no exception.
Withdraw consent. Where we rely on your consent, you can withdraw it at any time. This does not affect the lawfulness of what we did before you withdrew it.
Rights relating to automated decision-making. We do not make decisions about you by automated means that produce legal effects or similarly significantly affect you, and we do not carry out profiling of that kind.
How to exercise them
Email hello@standpointmag.co.uk, marking your message “Data protection request”, and tell us which right you want to exercise. If you are in the UK you may instead contact our UK representative at the address in clause 1, and we will treat the request as made to us on the day the representative receives it.
You will not have to pay a fee. We may ask you to confirm your identity — we are not going to hand your data to someone who has simply claimed to be you. We will respond within one month. If your request is complex, or if you have made several requests, we may extend that by up to two further months; we will tell you within the first month if that happens, and why.
Complaints
If you are unhappy with how we have handled your data, please tell us first — we would rather fix it. But you have the right to complain to a supervisory authority at any time.
In the United Kingdom, the Information Commissioner’s Office:
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
ico.org.uk/make-a-complaint
Readers in the EEA may complain to the supervisory authority in their own country. Readers elsewhere may complain to their local data protection authority where one exists.
11. Cookies
We use cookies and similar technologies. Non-essential cookies are only set where you have given consent, and you can change or withdraw that consent at any time.
Full detail, including what each cookie does and how long it lasts, is in our Cookie Policy.
12. Children
The Site is not directed at children, and we do not knowingly collect personal data from anyone under 13.
If you are under 13, please do not sign up to our newsletter or send us your details. If you believe a child has given us personal data, tell us at hello@standpointmag.co.uk and we will delete it.
13. Other websites
The Site links to other websites, and archive articles link to sites that in some cases no longer exist. This policy applies only to standpointmag.co.uk. We are not responsible for the privacy practices of other sites, and we would encourage you to read their policies.
14. Changes to this policy
We may update this policy. The version in force is the one on this page, and the date at the top tells you when it last changed.
If we make a material change — a new purpose, a new category of recipient, a change to the lawful basis for something — we will tell newsletter subscribers by email before it takes effect.
15. Contact
hello@standpointmag.co.uk
Briarwood International LLC
3301 Chetumal Street
Belize City
Belize
UK representative: hello@standpointmag.co.uk