Privacy policy
Last updated: June 2025
1. Introduction
Open Emotion Wheel (“we,” “our,” or “us”) respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, and protect your information when you visit our website openemotionwheel.com (the “Service”).
This policy complies with the EU General Data Protection Regulation (GDPR) and other applicable data protection laws.
2. Data Controller
The data controller responsible for your personal data is:
Open Emotion Wheel
Email: d.thorpe@adelaide.edu.au
3. What Personal Data We Collect
3.1 Information You Provide Directly
– Contact information (name, email address, phone number)
– Messages or inquiries submitted through contact forms
– Newsletter subscription data
– Account information (if applicable)
3.2 Information Collected Automatically
When you visit our website, we automatically collect certain information through cookies and similar technologies:
– Google Analytics Data: Including but not limited to:
– IP address (anonymized)
– Browser type and version
– Operating system
– Pages visited and time spent on pages
– Referring website
– Geographic location (country/city level)
– Device information
– User interactions and behavior patterns
– Technical Data:
– Cookies and tracking technologies
– Log files and server data
– Website usage statistics
4. Legal Basis for Processing
We process your personal data based on the following legal grounds under GDPR Article 6:
– Consent (Article 6(1)(a)): For Google Analytics tracking, marketing communications, and non-essential cookies
– Legitimate Interest (Article 6(1)(f)): For website security, fraud prevention, and essential website functionality
– Contract Performance (Article 6(1)(b)): When processing is necessary to fulfill services you’ve requested
– Legal Obligation (Article 6(1)(c)): When required by law
5. How We Use Your Personal Data
5.1 Google Analytics
We use Google Analytics to:
– Analyze website traffic and user behavior
– Improve website performance and user experience
– Generate statistical reports on website usage
– Understand demographic information about our visitors
Google Analytics uses cookies to track your activity across our website. The data collected is processed by Google LLC in the United States.
5.2 Other Uses
– Respond to your inquiries and provide customer support
– Send marketing communications (with your consent)
– Improve our website and services
– Ensure website security and prevent fraud
– Comply with legal obligations
6. Data Sharing and Third Parties
6.1 Google Analytics
Your data collected through Google Analytics is shared with:
– Google LLC: As the service provider for analytics services
– Data is transferred to and processed in the United States
– Google processes this data according to their privacy policy and data processing terms
6.2 Other Third Parties
We may share your data with:
– Service providers who assist in website operation
– Legal authorities when required by law
– Business partners (only with your explicit consent)
We do not sell your personal data to third parties.
7. Data Transfers Outside the EU
Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including:
– United States: Google Analytics data is processed by Google LLC in the US
– Adequate Protection: We ensure transfers are protected by appropriate safeguards such as:
– EU Standard Contractual Clauses
– Adequacy decisions by the European Commission
– Binding Corporate Rules
8. Data Retention
– Google Analytics Data: Automatically deleted after 26 months (or as configured)
– Contact Form Data: Retained for 3 years or until you request deletion
– Marketing Communications: Until you unsubscribe or withdraw consent
– Legal Requirements: Some data may be retained longer if required by law
9. Cookies and Tracking Technologies
9.1 Types of Cookies We Use
Essential Cookies: Necessary for website functionality
Analytics Cookies: Google Analytics cookies for website performance analysis
Marketing Cookies: For advertising and marketing purposes (with consent)
9.2 Google Analytics Cookies
Google Analytics uses the following cookies:
– `_ga`: Distinguishes users (expires after 2 years)
– `_gid`: Distinguishes users (expires after 24 hours)
– `_gat`: Throttles request rate (expires after 1 minute)
9.3 Managing Cookies
You can control cookies through:
– Our cookie consent banner
– Your browser settings
– Google Analytics opt-out browser add-on
– Directly through Google’s privacy controls
10. Your Rights Under GDPR
You have the following rights regarding your personal data:
10.1 Right of Access (Article 15)
Request information about how your personal data is processed
10.2 Right to Rectification (Article 16)
Correct inaccurate or incomplete personal data
10.3 Right to Erasure (Article 17)
Request deletion of your personal data (“right to be forgotten”)
10.4 Right to Restrict Processing (Article 18)
Limit how we use your personal data
10.5 Right to Data Portability (Article 20)
Receive your data in a structured, machine-readable format
10.6 Right to Object (Article 21)
Object to processing based on legitimate interests or for direct marketing
10.7 Right to Withdraw Consent (Article 7)
Withdraw consent at any time for consent-based processing
10.8 Right to Lodge a Complaint
File a complaint with your local data protection authority
11. How to Exercise Your Rights
To exercise any of your rights, contact us at:
– Email: david@coolout.co
We will respond to your request within one month of receipt.
11.1 Google Analytics Opt-Out
To opt out of Google Analytics tracking:
– Use Google’s opt-out browser add-on
– Adjust your cookie preferences on our website
– Use browser settings to block analytics cookies
12. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including:
– Encryption of data in transit and at rest
– Regular security assessments
– Access controls and authentication
– Staff training on data protection
13. Children’s Privacy
Our website is not intended for children under 16. We do not knowingly collect personal data from children under 16. If you believe we have collected such data, please contact us immediately.
14. Changes to This Privacy Policy
We may update this privacy policy from time to time. When we make changes:
– We will update the “Last updated” date
– For significant changes, we will notify you via email or website notice
– Continued use of our website constitutes acceptance of changes
15. Contact Information
15.1 General Inquiries
For questions about this privacy policy or our data practices:
Email: d.thorpe@adelaide.edu.au
