PRIVACY POLICY

 

We (“we”, or “us”) recognize the importance of privacy. We want you to feel confident using our services, and this privacy notice (“Privacy Notice” or “Notice”) is to help you understand and describe how we collect, use, and disclose your information.

 

This Notice describes the following:

  • What information we collect and how it is collected;

  • How we use the information;

  • With whom we may share information;

  • Legal basis for processing the information;

  • Your rights and choices;

  • Security and storage of the information;

  • Third-party websites;

  • Changes to the Notice; and

  • Contacting us.

 

Throughout this document, any text, data, information, software, graphics, photographs and more that we or our affiliates may make available to you, plus our websites and any services, plug-ins, software, or applications that we may provide all together constitute our “Website.” 

Information We Collect

We collect information about you directly from you and automatically through your use of our Website. We may combine information automatically collected with other information that we have collected about you including from publicly available sources.

 

Information Provided Voluntarily

In order to help you protect yourself and your information, we encourage you to provide only that information that is necessary. For example, to request we contact you, you only need to provide us with a name, email address, and contact number

Our products and services are not directed to children under thirteen (13) years of age and we do not knowingly collect Personal Information from children under 13. If we discover that a child under 16 has provided us with Personal Information, we will promptly delete such Personal Information from our systems.

 

Information Collected Automatically

Like many websites, we and our Service Providers use Cookies, web beacons, and other technologies to receive and store certain types of information when you interact with us through your computer or mobile device subject to your opt-out preferences. Using these technologies helps us customize your experience with our Website, improve your experience, and tailor marketing messages. Here are some of the types of information we collect:

  • Log & Device data. Our servers may automatically record information (“log data”), including information that your browser sends whenever you visit our Website. This log data may include the web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, and time zone or location. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please check the policies of your device manufacturer or software provider.

  • Cookie data. Depending on how you’re accessing our services and subject to your opt-out preferences, we may use “Cookies” (a small text file sent by your computer each time you visit our Website, unique to your account or your browser) or similar technologies to record log data. When we use Cookies, we may use ‘session’ Cookies (that last until you close your browser) or ‘persistent’ Cookies (that last until you or your browser deletes them). For example, we may use Cookies to keep you logged into one of our products or services. Some of the Cookies we use may be associated with your account (including personal information about you, such as the email address you gave us), and other Cookies are not.

  • Other Web Site Analytics Services. Subject to your opt-out preferences (see ‘Your Rights and Choices’ below), we use third-party Service Providers such as Google Analytics to provide certain analytics and Viewer interactions services to us in connection with our operation of our Website, including the collection and tracking of certain data and information regarding the characteristics and activities of visitors. You may opt-out of relevant cookies using opt-out features on their respective websites.

 

How We Use Your Information

We may use information that we collect about you, including Personal Data, to:

  • Provide a Service. We will use your information to provide our Website to you; including facilitating scheduling; managing your account; responding to your inquiries; and for other customer service and support purposes. We use payment information you provide to us in order to alert you of past, current, and upcoming charges, to allow us to present the billing history to you on your billing page in the Website, and to perform internal financial processes, such as looking at the status of a credit card charge. In the event of a credit card dispute, we also share account information with your bank to verify the legitimacy of a charge.

  • Understand and improve our products. We will perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others. We do this to help make our products better and to develop new products.

  • Communicate with you.

    • Service-related communications. We may send you service and administrative emails to ensure our product or service is working. We will also email you. These messages are considered part of our service and you may not opt out of these messages.

    • Promotional. Subject to your opt-out preference, we may send you emails about new product features or other news or on topics we think would be relevant to you. You may opt out of receiving these communications at any time. Visit the ‘Your Rights and Choices’ section below. For Invitees, please be assured that we do not use the email addresses to send any type of direct marketing.

    • Responding to your requests. We will also use your information to respond to your questions or comments.

    • Administrative. We may contact you to inform you about changes in your services, our service offering and other important service-related notices, such as changes to the Notice or about security or fraud notices.

  • Protecting Rights and Interests. We will use your information to protect our rights and interests as well as the rights and interests of our Users and any other person, as well as to enforce this Notice or our Terms of Use.

  • Legal Compliance. We may use your information to comply with applicable legal or regulatory obligations, including complying with requests from law enforcement or other governmental authorities, or in legal proceedings.

  • Other. We also may use your information to manage our business or perform functions as otherwise described to you at the time of collection subject to your consent.

 

With Whom We May Share Your Information

We do not sell your information to any third parties or disclose it in exchange for money or other valuable consideration. We do not share your Personal Data with others except as indicated within this Notice, or when we inform you and give you an opportunity to opt-out of having your Personal Data shared.

We may share information we collect about you, including Personal Data, in the following ways:

  • With third-party Service Providers, agents, contractors, or government entities.

We may use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you:

We may engage Service Providers to process credit card transactions or other payment methods. We may also engage Service Providers to provide services such as monitoring and developing services; aiding in communications, infrastructure, and IT services; customer service; debt collection; analyzing and enhancing data. These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the above-listed types of information that we request may be collected by third-party Service Providers on our behalf.

We may share information with Service Providers and government entities for legal, security, and safety purposes. This includes sharing information in order to enforce policies or contracts, address security breaches, and assist in the investigation of fraud, security issues, or other concerns.

We require Service Providers to agree to take reasonable steps to keep Personal Data that we provide to them secure. We do not authorize them to use or disclose your Personal Data except in connection with providing their services.

  • Affiliates.

We may disclose information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Notice.

We may share your data if we believe that disclosure is reasonably necessary to comply with a law, regulation, legal, or governmental request; to respond to a subpoena, court order, warrant, or other legal process; to enforce applicable Terms of Use or this Notice, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or us; to detect, prevent, or otherwise address, security or technical issues, illegal, or suspected illegal activities (including fraud); or as evidence in litigation in which we are involved, as part of a judicial or regulatory proceeding.

 

Your Rights and Choices

  • E-mail. As described above, if you do not wish to receive promotional emails from us, you may opt out at any time by following the opt-out link contained in the email itself. Please note that it may take up to ten (10) days to process your request. 

  • Cookies. You may also refrain from providing or may withdraw your consent for Cookies via your browser settings or via limited opt-out functions within our products and services. Your browser’s help function should contain instructions on how to set your computer to accept all Cookies, to notify you when a Cookie is issued, or to not receive Cookies at any time.

  • Third Party Analytics Services. Some of the services used provide the ability to opt-out. You may opt out of Google Analytics’ services using the Opt-Out feature on their website. The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: https://tools.google.com/dlpage/gaoptout.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/policies/privacy.

  • Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.

 

Security and Storage of Information

We have taken reasonable steps to help protect the personal information we collect. More information on our security and storage practices is available on request. 

We take the security of your personal data very seriously. We work hard to protect the personal data that you provide from loss, misuse, and unauthorized access, or disclosure. Given the nature of communications and information processing technology, there is no guarantee that personal data will be absolutely safe from access, alteration, or destruction by a breach of any of our physical, technical, and managerial safeguards. 

We retain the personal data we collect for so long as is reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.

 

Third-Party Links

Our Website may contain links to third-party websites and applications. Subject to your opt-out preferences (see Your Rights and Choices), we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our Website. Any access to and use of such linked websites and applications is not governed by this Notice but instead is governed by the privacy policies of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.

 

Users Outside the UK and the USA

Application and database servers for our products and services will normally be located within the USA or the UK. Our preferred supplier has certified with the US Department of Commerce that it adheres to the Privacy Shield Principles under the EU-U.S. Privacy Shield framework and the Swiss-U.S. Privacy Shield framework.

If you are an individual located in the European Economic Area, Canada or another jurisdiction outside of the United States or United Kingdom with laws and regulations governing personal data collection, use, and disclosure that differ from United States or UK laws, please be aware that information we collect (including through the use of methods such as Cookies and other web technologies) will be processed and stored in the United States or UK or in other countries where we or our third-party Service Providers have operations. By submitting your personal data and using our products and services, you expressly consent to have your personal data transferred to, processed, and stored in the United States or UK or another jurisdiction which may not offer the same level of privacy protection as those in the country where you reside or are a citizen.

 

Do Not Track

We do not currently recognize or respond to browser initiated Do Not Track signals as there is no consistent industry standard for compliance.

 

Dispute Resolution

For any complaints that cannot be resolved with us directly, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by our means. Further details regarding our dispute resolution process are available upon request.

 

Changes to this Notice

This Notice is current as of the Effective Date set forth below. This Notice may change if there is a material change to the way we handle information, or to clarify our Notice or adjust clerical errors. If any changes are made, we’ll post them on this page, so please be sure to check back periodically. If you continue to use our products and services after those changes are in effect, you agree to the revised Notice.

 

Contacting Us

If you have any questions or comments about this Notice, please contact us directly, using the relevant Contacts page on our website.

STEPHAN COLLINA  AUTHOR stephan@stephancollina.com         © 2020 Stephan Collina