Last Updated and Effective as of: 2nd August, 2020
Stephanie Owen (hereinafter, the “Company”, “we”, “our” or “us”) respects the privacy concerns of the users of its website, www.stephanie-owen.com and the services provided therein (the “Site”). The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information may be used.
Your provision of your personal information to us is completely voluntary. “Personal information” is information that can specifically identify you. We do not collect personal information unless you submit that information to us.
Categories of personal information we may collect include:
• Identity Data, which includes name or other similar identifiers.
• Contact Data, which includes address, email address and telephone numbers.
Additionally, we may also collect certain others types of information that, along with Identity Data and Contact Data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:
• Financial Data, which includes credit card, debit card or other payment card details.
• Transaction Data, which includes details about payments to and from you.
• Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information.
• Profile Data, which includes your username and password, avatar (if you upload one) and other info you share with us on our Website.
• Usage Data, which includes information about how you use our Website and advertising we serve on those sites.
• Marketing and Communications Data, which includes your preferences in receiving marketing from us.
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your information by registering or contacting us. This includes information you provide when you:
• create an account on our website;
• subscribe to our service or publications;
• purchase product(s) on our website(s)
• request marketing to be sent to you; or
• give us feedback.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data and Usage Data about you.
Some of the ways in which we or our website may collect are further described below:
- Interest-Based Advertising: We may engage third-party vendors to use your information in connection with their own information to deliver targeted advertising to you when you visit our website or other websites. Cookies, described above, may be used in this process. For example, if you are searching for information on a particular product, our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising is called “behavioral advertising”. We believe that such advertising is helpful because you will see ads that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the Opt-Out section below.
- Clickstream Data: As you use the Internet, a trail of electronic information is left at each website you visit. This information, sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. For example, clickstream data can tell the type of computer and browsing software you use and the address of the website from which you linked to the website. The website may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website, how visitors navigate throughout the Website and how we may tailor our website to better meet the needs of visitors. This information often will be used to improve our website and our services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any personal information.
INFORMATION USE AND SHARING
Subject to the section titled “Additional EU Disclosures”, we use information held about you to perform our services and for other purposes outlined below. Specifically, we use your information for a variety of purposes:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- To perform specific services that you have requested.
To respond to your direct inquiries.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- To send you marketing materials (see below).
- Where we need to comply with a legal or regulatory obligation.
Subject to the section titled “Additional EU Disclosures”, we may share the information we collect about you with certain third parties in the following ways:
- To use certain services on our website, payment card information may be requested. We may ask you for credit card, debit card, or other payment information. By submitting your payment information through our websites, to the extent permitted by applicable law, you expressly consent to the sharing of your information with third-party payment processors, and other third-party service providers.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them, if we are part of a bankruptcy proceeding or other change in control.
- Third parties to whom we need to share your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the website.
LINKS TO EXTERNAL WEBSITES AND SOCIAL NETWORKING SERVICES
The Website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.
Security for all personally identifiable information is extremely important to us. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, The Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to the Company, you accept that you do so at your own risk.
Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.
We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
PROVISION OF PERSONAL DATA AND FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.
WITHDRAWING YOUR CONSENT
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at firstname.lastname@example.org
USE OF YOUR PERSONAL DATA FOR MARKETING PURPOSES
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
• Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
To see how you can opt out of marketing communications, please see the section titled “Opt-Out” found at the bottom of all of our email communications.
ADDITIONAL EU DISCLOSURES
RIGHTS OF EU DATA SUBJECTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. you have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
To exercise your rights, please contact us at email@example.com
The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us, including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.
OPTING OUT OF COOKIES
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge.
Children Age 18 and Under:
The Company recognizes the special obligation to protect personally identifiable information obtained from children age 18 and under. AS SUCH, IF YOU ARE 18 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 18 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.
Transfer of Information Across National Borders
Our site and various information we collect are operated on servers located in various jurisdictions. When you access or use the Site and/or our services, personal information about you may be transferred outside the country in which you are situated to these other locations. We ensure that appropriate contracts containing standard data protection clauses approved by the European Commission to protect that information and the rights of individuals are in place with any and all third-party service providers we may use.
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