pubwatch, together with its affiliated companies) collect and use information pertaining to each of our
unregistered visitors and registered users, in connection with their access to and use of West Conwy
pubwatch websites (including www.westconwypubwatch.co.uk and any of its sub domains, the “Website”),
mobile applications (“Mobile Apps”), and related services (collectively, the “Services”).
collect and use your personal information, as well as an explanation of your statutory rights. This Privacy
Policy is not intended to override the terms of any contract you have with us, nor any rights you might have
under applicable data privacy laws.
Read this policy and make sure you fully understand our practices in relation to your personal information,
remain opposed to our practices, you must immediately leave this website, application or service, and avoid
or discontinue all use of any of our Services. If you have any questions or concerns regarding this
policy, please contact us at westconwypubwatch.co.uk.
2. What information do we collect?
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users:
Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be
made available to us, or collected automatically via his/her use of the Services (“Non-personal
Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom
it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated
usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session
heat maps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system,
internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit
pages, date/time stamps, etc.
Individually identifiable information, namely information that identifies an individual or may with
reasonable efforts cause the identification of an individual, or may be of private or sensitive nature
(“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g.,
e-mail address or phone number), billing details (name, physical billing address, payment method and
transaction details), which are only collected from Users with Paid Services, details regarding a browsing or
usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third
party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account),
scanned identification documents provided to us (such as an ID card, driver’s license, passport or official
company registration documents), correspondences (including those made through or uploaded to our
Services), and any other Personal Information provided to us by Visitors and/or Users through their access to
and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or
linked to Personal Information (for example, in order to improve the Services we offer) is deemed and
treated by us as Personal Information, as long as such connection or linkage exists.
2.2. Users of Users Information
We may also collect similar information pertaining to visitors and users of our User’s websites or
services (“Users-of-Users”), solely for and on our Users’ behalf.
3. How do we collect such information?
There are two main methods we use:
We collect information through your use of the Services. When you visit or use our Services, including when
you browse the Website or any User Website, register a User Account, edit your User Website and upload
information and content, and/or download and use any Forms and/or Mobile Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or
with the help of third-party services as detailed in Section 8 below, including through the use of “cookies”
and other tracking technologies, as further detailed in Section 9 below.
We collect information which you provide us voluntarily. For example, we collect the Personal Information
you provide us when you register to our Services;
We also collect information from third party sources as described in Section 8 below.
4. Why do we collect such information?
We collect such Non-personal and Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal
preferences, experiences and difficulties;
To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Visitors and Users with general or personalized service-related notices and
promotional messages (as further detailed in Section 10 below);
To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility,
monitor performance, contact winners and grant prizes and benefits;
To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which
we or our business partners may use to provide and improve our respective services;
To enhance our data security and fraud prevention capabilities; and to comply with any applicable laws and
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract
with you (e.g. to provide you with a website builder, to provide you with our customer assistance and
technical support), or
our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation
that we have, provided it is conducted at all times in a way that is proportionate, and that respects your
5. Where do we store your information?
West Conwy Pubwatch.co.uk is based in the county of Conwy, which is considered by the European
Commission to be offering an adequate level of protection for the Personal Information of EU Member State
West Conwy pubwatch affiliates and service providers that store or process your Personal Information on
West Conwy Pubwatch behalf are each contractually committed to keep it protected and secured, in
accordance with industry standards and regardless of any lesser legal requirements which may apply in their
Westconwypubwatch.co.uk is responsible for the processing of Personal Information it receives, under the
Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on its behalf.
Westconwypubwatch.co.uk complies with the Privacy Shield Principles for all onward transfers of Personal
Information from the EU, including the onward transfer liability provisions.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding
arbitration when other dispute resolution procedures have been exhausted.
Upon request West Conwy Pubwatch will provide you with information about whether we hold any of your
Personal Information. You may access, correct, or request deletion of your Personal Information by
following the instructions provided in these Help Center articles: “GDPR: Retrieving Your West Conwy
Pubwatch Account Data” or “GDPR: Permanently Deleting Your West Conwy Pubwatch Account. We will
respond to your request within a timeframe imposed by local laws or a reasonable timeframe.
Please note that permanently deleting your West Conwy Pubwatch account erases all of your information
from West Conwy Pubwatch databases. After completing this process, you can no longer use any of your Pubwatch Services, your User Account and all its data will be removed permanently, and West Conwy
Pubwatch will not be able to restore your account or retrieve your data in the future.
West Conwy Pubwatch data storage providers are contractually committed to protect and secure your data.
Among other things, West Conwy Pubwatch adheres to the EU – Privacy Shield Principles, for
further protecting and enhancing our users’ privacy.
Data Localisation Obligations: If you reside in a jurisdiction that imposes “data localisation” or “data
residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial
boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal
Information within such territorial boundaries, if we are legally obligated to do so.
You acknowledge that while doing so, we may continue to collect, store and use your Personal Information
elsewhere, including in the United States of America as explained above.
6. Users-of-users’ information
West Conwy Pubwatch may collect, store and process certain Non-personal and Personal Information of
Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For
example, each of our Users is able to import their e-mail contacts from third party services like Gmail, or
otherwise collect and manage contacts via their User Website. Such contacts are then stored with West
Conwy Pubwatch, on the User’s behalf.
For such purposes, West Conwy Pubwatch serves and shall be considered as a “Processor” and not as the
“Controller” (as both such capitalized terms are defined in the European Union General Data Protection
Regulation) of such Users-of-Users Information. The Users controlling and operating such User Websites
shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for
complying with all laws and regulations that may apply to the collection and control of such Users-of-Users
Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal
Information, and for obtaining consents, permissions and providing any fair processing notices required for
the collection and usage of such information.
West Conwy Pubwatch cannot provide legal advice to Users or their Users-of-Users, however we do
recommend that all Users publish and maintain clear and comprehensive privacy policies on their User
Websites, in accordance with the applicable laws and regulations, and that all Users-of-Users carefully read
those policies and make sure that they consent to them.
If you are a visitor, user or customer of any of our Users, please read the following: West Conwy Pubwatch
has no direct relationship with the individual Users-of-Users whose Personal Information it processes. If you
are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding
your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct,
amend, or delete inaccurate information processed by West Conwy Pubwatch on behalf of its Users, please
direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any
Users-of-Users’ Personal Information, we will respond to such request within thirty (30) days. Unless
otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set
forth in Section 13 below.
7. Sharing personal information with third parties
West Conwy Pubwatch may share your Personal Information with third parties (or otherwise allow them
access to it) only in the following manners and instances:
7.1. Third Party Services:
West Conwy Pubwatch has partnered with a number of selected service providers, whose services and
solutions complement, facilitate and enhance our own. These include hosting and server co-location services,
communications and content delivery networks (CDNs), data and cyber security services, billing and
payment processing services, domain name registrars, fraud detection and prevention services, web analytics,
e-mail distribution and monitoring services, session recording and remote access services, performance
measurement, data optimization and marketing services, content providers, and our legal and financial
advisors (collectively, “Third Party Service(s)”). own management tools for removing or blocking such technologies. Additional information about managing
Flash cookies is available here.
(Please note that this website is not provided by West Conwy Pubwatch, and we therefore cannot ensure its
accuracy, completeness or availability).
Behavioral Targeting/Re-Targeting: Certain Third Party Services and ad networks may display advertising on
our Website, mobile apps, or manage our advertising on other websites. Such parties may use certain tracking
technologies to collect certain information about your activities on the Services and different third party
Services to provide you with targeted advertising based on your interests and preferences. You may opt-out
of receiving targeted ads from certain advertisers and ad networks by clicking here (or if you are located in
the European Union click here (provided by YourChoicesOnline.eu). Please note this does not opt you out of
receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will
continue to receive advertising for which you have not opted out.
User Data Supplementation: We may receive information about you from other sources, including publicly
available databases or third parties from whom we have purchased data, and combine this data with
information we already have about you. This helps us to update, expand and analyze our records, identify
new customers, and provide products and Services that may be of interest to you. Where we obtain your
Personal Information from these third parties, we ensure that such parties are contractually committed to
inform you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of
your Personal Information before using it. If you provide us personal information about others, or if others
give us your information, we will only use that information for the specific reason for which it was provided
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track”
signal in the HTTP header from a browser or mobile application.
9. Communications from West Conwy Pubwatch
9.1. Promotional Messages:
We may use your Personal Information to send you promotional content and messages by e-mail, text
messages, direct text messages, marketing calls and similar forms of communication from West Conwy
10. Your rights in relation to your personal information
It is imperative that you have control over your Personal Information. That’s why West Conwy Pubwatch is
taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your
Before disclosing the requested Personal Information, we may ask you for additional information in order to
confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law
(e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still
recommend that you contact us first).
If you are a West Conwy Pubwatch Visitor or User, and you wish to receive a copy, access and/or request us
to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-
Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third
parties for direct marketing purposes, please Email your request to firstname.lastname@example.org
We will make all reasonable efforts to honor your request promptly (unless we require further information
from you in order to fulfil your request), subject to legal and other permissible considerations.
Please note that permanently deleting your West Conwy Pubwatch account erases all of your information
from West Conwy Pubwatch databases. After completing this process, you can no longer use any of your
West Conwy Pubwatch services, your account and all its data will be removed permanently, and West Conwy
Pubwatch will not be able to restore your account or retrieve your data in the future. 11. Questions and Complaints
If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if
Our Data Protection Officer team will investigate the complaint and determine whether a breach has
occurred and what action, if any, to take.
We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint
promptly. Our target response time is 30 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain
dissatisfied, you can also make a complaint with your local supervisory authority for data protection.
You can file a complaint with your local supervisory authority for data protection at any time, however we
recommend that you contact us first so we can try to resolve it.
12. Data Retention
We may retain your Personal Information (as well as your Users-of-Users’ Information) for as long as your
We may continue to retain such Personal Information even after you deactivate your User Account and/or
cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve
disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or
protect our legitimate interests.
We maintain a data retention policy which we apply to information in our care. Where your Personal
Information is no longer required we will ensure it is securely deleted.
West Conwy Pubwatch has implemented security measures designed to protect the Personal Information you
share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS
secure access to most areas on our Services; the transmission of sensitive payment information (such as a
credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS
encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security
Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and
regularly seek new ways and Third Party Services for further enhancing the security of our Services and
protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by West Conwy Pubwatch, we cannot and do not guarantee the
absolute protection and security of your Personal Information, your Users-of-Users’ Information or any other
User Content you upload, publish or otherwise share with West Conwy Pubwatch or anyone else.
We therefore encourage you to set strong passwords for your User Account and User Website, and avoid
providing us or anyone with any sensitive information of which you believe its disclosure could cause you
substantial or irreparable harm. Furthermore, because certain areas on our Services are less secure than
others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you
browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of
communications, we request and encourage you not to share any Personal Information on any of these areas
or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at
14. Public forums and user content
Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any
information you provide in any such areas may be read, collected, and used by others who access them. To
request removal of your Personal Information from our blogs, communities or forums, feel free to contact us
at: email@example.com. In some cases, we may not be able to remove your Personal Information
from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook
social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that
In any event, we advise against posting any information (or use any posting means to post information) you
don’t wish to publicize on these platforms.
If you upload any User Content to your User Account or post it on your User Website and provide it in any
other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. However, we cannot
control the actions of other Users or members of the public who may access your User Content, and are not
responsible for the circumvention of any privacy settings or security measures you or we may have placed on
your User Website (including, for instance, password-protected areas on your User Website). You understand
and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in
cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or
stored such User Content. To clarify, we advise against uploading or posting any information you do not
wish to be public.
15. Updates and interpretation
collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good
faith discretion), we will notify you prior to the change becoming effective. We encourage you to
periodically review this page for the latest information on our privacy practices.
and your Users-of-Users, with respect to our Website and Mobile Apps.
16. Contacting us
please contact us by email at firstname.lastname@example.org. We will attempt to resolve any complaints