Updated 10 September 2020.
INFORMATION COLLECTION, BUSINESS PURPOSE AND USEWhile using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to name, email address, cookies, usage data, password. We may use your personal information to
- send you our newsletters from time to time (usually once per week)
- manage contacts and send messages
- ensure that content from our site is presented in the most effective manner for you and for your computer
- provide you with information, products or services that you request from us which may be of interest to you
- carry out our obligations arising from any contracts entered into between you and us
- interact with external social networks and platforms (e.g. social media widgets and share bars)
- allow registration and authentication (e.g. affiliate portals and membership areas)
- allow access to third party services’ accounts
- monitor infrastructure
- manage hosting and backend infrastructure
- interact with live chat platforms
- carry out remarketing and behavioural targeting (including display ads)
- display content from external platforms
- carry out commercial affiliation (e.g. display ads)
- interact with support and feedback platforms
- manage user database
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s and GDPR’s scope
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment – related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Log dataLike many site operators, we collect information that your browser sends whenever you visit our Site. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this data.
LAWFUL BASIS OF PROCESSING PERSONAL DATA UNDER THE GDPRWe may process personal data relating to users if one of the following applies:
- users have given their consent for one or more specific purposes;
- provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
DATA RETENTIONWe process and store your personal data for as long as required by the purpose they have been collected for. Therefore:
- personal data collected for purposes related to the performance of a contract between us and the user will be retained until such contract has been fully performed;
- personal data collected for the purposes of our legitimate interests will be retained as long as needed to fulfill such purposes;
- we may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn;
- we may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
THIRD-PARTY DISCLOSUREWe do not sell, trade, or otherwise transfer to outside parties your personal information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users (such as, for example, our email provider Convertkit), so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Category A: Identifiers Category B: California Customer Records personal information categories Category D: Commercial information. Category F: Internet or other similar network activity. Category G: Geolocation data. We disclose your personal information for a business purpose to the following categories of third parties:
- Professional service providers.
- Third parties whose services you purchase through our Site.
- Social Media Networks.
YOUR RIGHTS UNDER THE GDPRUsers based in the European Union have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.
- Object to processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent.
- Access their data. Users have the right to learn if data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
- Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, we will not process their data for any purpose other than storing it.
- Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from us.
- Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any undue delay.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection supervisory authority.
YOUR RIGHTS UNDER THE CCPAUsers who reside in California have the right to request any of the following
- disclosure of the categories and specific pieces of personal information we have collected
- deletion of personal information we have collected from you
- disclosure of the categories of personal information we have collected, the categories of sources from which we collected it, the business or commercial purpose for collecting or selling it, the categories of third parties with whom we share it, and the specific pieces of personal information we have collected
- disclosure of the categories of personal information we collected or sold and the categories of third parties to whom it was sold
- You have the right not to receive discriminatory treatment for the exercise of these privacy rights.
YOUR RIGHT TO OPT OUT OF THE SALE OF PERSONAL INFORMATIONUnder the CCPA, “sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. As per the CCPA definition, selling personal information includes disclosing information to a third party by using analytics tools, running ads or having social media pixels and plugins installed. Users who reside in California have the right to opt out of the sale of personal information. Requests to exercise your right to opt out can be submitted by you or someone legally authorized to act on your behalf by email to firstname.lastname@example.org.
SECURITYThe security of your personal information is important to us. Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Site as safe as possible. We use regular Malware Scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers. Unfortunately, no method of transmission over the internet is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.