Privacy Policy

Thank you for your interest in this website, which is operated by Graeme Cumming. This page informs you of policies regarding the collection, use and disclosure of personal data when you use the Service and the choices you have associated with that data.

It is Graeme Cumming’s policy to respect your privacy regarding any information collected from you or which you may provide, in the circumstances set out below. Accordingly, this privacy policy has been developed in order for you to understand how your personally identifiable information (“Personal Data”) is collected, communicated, disclosed, safeguarded and otherwise made use of.

For the purposes of the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”), Graeme Cumming is the “data controller”. If you have any questions about this policy or about how your Personal Data is used, please contact him via the email address at the end of this policy.

This policy is effective as of 01.12.18. Privacy practices are reviewed on an ongoing basis and, as such, this privacy policy may change from time to time. Please check this page frequently to ensure you are familiar with its current content.

Types of Data Collected

Personal Data

While using this website, you may be asked to provide certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Cookies and Usage Data

Your Personal Data may be used to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications by contacting Graeme Cumming using the email at the end of this policy.

Usage Data

Information about how the Service is accessed and used (“Usage Data”) may also be collected. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

 Tracking & Cookies Data

Cookies and similar tracking technologies may be used to track the activity on the service and hold certain information.

Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse the Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Service.

Examples of Cookies used are:

  • Session Cookies. Session Cookies are used to operate the service.
  • Preference Cookies. Preference Cookies are used to remember your preferences and various settings.
  • Security Cookies. Security Cookies are used for security purposes.

Use of Data

Graeme Cumming uses the collected data for various purposes:

  • To provide and maintain the Service
  • To notify you about changes to the Service
  • To allow you to participate in interactive features of the Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that the Service can be improved
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which he offers that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Graeme Cumming’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data collected and the specific context in which it is collected.

Graeme Cumming may process your Personal Data because:

  • He needs to perform a contract with you
  • You have given him permission to do so
  • The processing is in his legitimate interests and it’s not overridden by your rights
  • To comply with the law

Retention of Data

Graeme Cumming will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. He will retain and use your Personal Data to the extent necessary to comply with his legal obligations (for example, if he is required to retain your data to comply with applicable laws), resolve disputes, and enforce his legal agreements and policies.

Graeme Cumming will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the service, or there is a legal obligation to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United Kingdom and choose to provide information to Graeme Cumming, please note that the data, including Personal Data will be transferred to the United Kingdom and processed there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Graeme Cumming will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Legal Requirements

Graeme Cumming may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Graeme Cumming
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your data is important to Graeme Cumming, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While he strives to use commercially acceptable means to protect your Personal Data, he cannot guarantee its absolute security. 

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Graeme Cumming aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data he holds about you and if you want it to be removed from his systems, please contact him.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information Graeme Cumming has on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact him to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to the processing of your Personal Data.
  • The right of restriction. You have the right to request that Graeme Cumming restricts the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information he has on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Graeme Cumming relied on your consent to process your personal information.

Please note that you may be asked to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about the collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

Graeme Cumming may employ third party companies and individuals to facilitate the Service (“Service Providers”), to provide the Service on his behalf, to perform Service-related services or to assist in analysing how the Service is used.

These third parties have access to your Personal Data only to perform these tasks on his behalf and are obligated not to disclose or use it for any other purpose.

Links to Other Sites

The Service may contain links to other sites that are not operated by Graeme Cumming. If you click on a third party link, you will be directed to that third party’s site. You are strongly advised to review the Privacy Policy of every site you visit.

Graeme Cumming has no control over and assumes no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

The Service does not address anyone under the age of 18 (“Children”).

Graeme Cumming does not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided him with Personal Data, please contact him. If he becomes aware that he has collected Personal Data from children without verification of parental consent, he takes steps to remove that information from his servers.


When visitors leave comments on the site Graeme Cumming collects the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: After approval of your comment, your profile picture is visible to the public in the context of your comment.


If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Changes to This Privacy Policy

This Privacy Policy may be updated from time to time. Any changes will be notified by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


If you have any questions about this Privacy Policy, please contact Graeme Cumming by email: