HOW TO HANDLETTER
PRIVACY POLICY AND COOKIE POLICY
10/7/2018
BACKGROUND:
How to Handletter understands that your privacy is important to you and that you
care about how your information is used and shared online. We respect and value
the privacy of everyone who visits Our Site and will only collect and use
information in ways that are useful to you and in a manner consistent with your
rights and Our obligations under the law. We collect only the information you
freely give Us about yourself.
This Policy applies to Our use of any and all data collected by us in relation to
your use of Our Site. Please read this Privacy Policy carefully and ensure that
you understand it. Your acceptance of Our Privacy Policy is deemed to occur
upon your first use of Our Site. If you do not accept and agree with this Privacy
Policy, you must stop using Our Site immediately.
DEFINITIONS AND INTERPRETATIONS
In this Policy the following terms shall have the following meanings:
“Account” – Means an account required to access and/or use certain areas and
features of Our Site;
“Cookie” – Means a small text file placed on your computer or device by Our Site
when you visit certain parts of Our Site and/or when you use certain features of
Our Site. Details of the Cookies used by Our Site are set out in a section below.
“Our Site” – Means this website, www.howtohandletter.com;
“United States of America and EU Cookie Law” – Means the relevant parts of the
Privacy and Electronic Communications (EC Directive) Regulations 2003 as
amended in 2004, 2011, 2015;
“We/Us/Our” – Means How to Handletter, whose address is 11923 NE Sumner
Street STE 734681, Portland, OR 97220
INFORMATION ABOUT US
Our Site, www.howtohandletter.com, is owned and operated by How to Handletter
SCOPE – WHAT DOES THIS POLICY COVER?
This Privacy Policy applies only to your use of Our Site. It does not extend to any
websites that are linked from Our Site (whether We provide those links or whether
they are shared by other users). We have no control over how your data is
collected, stored or used by other websites and We advise you to check the
privacy policies of any such websites before providing any data to them.
WHAT DATA DO WE COLLECT?
Some data will be collected automatically by Our Site. For further details, please
see the section below on Our use of Cookies. Other data will only be collected if
you voluntarily submit it and consent to Us using it, for example, when signing up
for an Account or email list. Depending upon your use of Our Site, We may collect
some or all of the following data:
- Name
- Contact information such as email addresses
- Financial information such as credit/debit card numbers
- IP address (automatically collected)
- Web browser type and version (automatically collected)
- Operating system (automatically collected)
- A list of URLs starting with a referring site, your activity on Our Site, and
the site you exit to (automatically collected)
HOW DO WE USE YOUR DATA?
All personal data is stored securely in accordance with the EU General
Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).
We use your data to provide the best possible products and services to
you. This includes:
- Providing and managing your access to Our Site
- Personalizing and tailoring your experience on Our Site
- Supplying Our products and services to you
- Personalizing and tailoring Our products and services for you
- Financial data such as credit card or bank transfer details. We collect
financial data in order to allow you to purchase, order, return or exchange
products or services from Our website and any related mobile apps. We
store limited financial data. Most financial data is transferred to Our
payment processors and You should review these processors’ Privacy
Policy to determine how they use, disclose and protect your financial data. - Responding to communications from you
- Supplying you with email (newsletters, alerts, promotions, updates, and
free downloadable content, courses, etc.) that you have subscribed to. You
may unsubscribe or opt-out at any time by clicking the unsubscribe button
at the bottom of any email you receive. - Market research
- Analyzing your use of Our Site and gathering feedback to enable Us to
continually improve Our Site and your use experience. - Targeted Social Media Advertisements. We may use the data you provide
to Us to run social media advertisements. - Social Networking Data: We may access personal information from social
networking sites and apps, including Facebook, Instagram, Linkedin,
Twitter, Snapchat or other social networking sites or apps not named
specifically here, which may include your name, your social network
username, location, email address, age, gender, profile picture and any
other public information. If you do not want Us to access this information,
please go to the specific social networking site and change your privacy
settings. - Mobile Device Data: If you use Our website via a mobile device or app, We
may collect information about your mobile device, including device ID,
model and manufacturer, and location information. - In some cases, the collection of data may be a statutory or contractual
requirement, and We will be limited in the products and services We can
provide you without your consent for Us to be able to use such data. - With your permission and/or where permitted by law, We may also use your
data for marketing purposes which may include contacting you by email
and/or posts with information, news and offers on Our products and
services. We will not, however, send you to any unsolicited marketing or
spam and will take all reasonable steps to ensure that We fully protect your
rights and comply with Our obligations under the GDPR and the Privacy
and Electronic Communications (EC Directive) Regulations 2003, as
amended in 2004, 2011, and 2015. - Advertisers whose content appears on Our Site may engage in what is
known as “behavioral advertising” – advertising which is tailored to your
preferences, based on your activity. Your activity is monitored using
Cookies, as detailed below. You can control and limit your data used in this
way by adjusting your web browser's privacy settings. Please note that We
do not control the activities of such advertisers, nor the information they
collect and use. Limiting the use of your data in this way will not remove the
advertising, but it will make it less relevant to your interests and activities on Our Site.
Under GDPR we will ensure that your personal data is processed lawfully,
fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis
applies: - You have given consent to the processing of your personal data for one or
more specific purposes; - Processing is necessary for the performance of a contract to which you are
a party or in order to take steps at the request of you prior to entering into a
contract; - Processing is necessary for compliance with a legal obligation to which we
are subject; - Processing is necessary to protect the vital interests of you or of another
natural person; - Processing is necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested in the controller;
and/or - Processing is necessary for the purposes of the legitimate interests
pursued by us or by a third party, except where such interests are
overridden by the fundamental rights and freedoms of the data subject
which require protection of personal data, in particular where the data
subject is a child.
HOW AND WHERE DO WE STORE YOUR DATA?
We only keep your data for as long as We need to in order to use it as described
above, and/or for as long as We have your permission to keep it. In any event,
We will conduct a periodic review to ascertain whether we need to keep your
data. Your data will be deleted if we no longer need it.
Some or all of your data may be stored or transferred outside of the European
Economic Area (“the EEA”) (The EEA consists of all EU member states, plus
Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this
by using Our Site and submitting information to Us. If We do store or transfer data
outside the EEA, We will take all reasonable steps to ensure that your data is
treated as safely and securely as it would be within the EEA and under the
GDPR. Such steps may include, but not be limited to, the use of legally binding
contractual terms between Us and any third parties We engage in the use of the
EU-approved Model Contractual Arrangements. If We intend at any time to
transfer any of your data outside the EEA, We will always obtain your consent
beforehand.
Data security is of great importance to Us, and to protect your data We have put
in place suitable physical, electronic and managerial procedures to safeguard and
secure data collected through Our Site.
Notwithstanding the security measures that We take, it is important to remember
that the transmission of data via the internet may not be completely secure and
that you are advised to take suitable precautions when transmitting to Us data via
the internet.
DO WE SHARE YOUR DATA?
We may contract with third parties to supply products and services to you on Our
behalf. These may include payment processing, delivery of goods, search engine
facilities, advertising and marketing. In some cases, the third parties may require
access to some or all of your data. Where any of your data is required for such a
purpose, We will take all reasonable steps to ensure that your data will be
handled safely, securely, and in accordance with your rights, Our obligations, and
the obligations of the third party under the law.
We may compile statistics about the use of Our Site including data on traffic,
usage patterns, user numbers, sales and other information. All such data will be
anonymized and will not include any personally identifying information. We may
from time to time share such data with third parties such as prospective investors,
affiliates, partners and advertisers. Data will only be shared and used within the
bounds of the law.
In certain circumstances We may be legally required to share certain data held by
Us, which may include your personal information, for example, where We are
involved in legal proceedings, where We are complying with the requirements of
legislation, a court order, or a governmental authority. We do not require any
further consent from you in order to share your data in such circumstances and
will comply as required with any legally binding request that is made of Us.
WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?
We may, from time to time, expand or reduce Our business and this may involve
the sale and/or the transfer of control of all or part of Our business. Data provided
by users will, where it is relevant to any part of Our business so transferred, be
transferred along with that part and the new owner or newly controlling party will,
under the terms of this Privacy Policy, be permitted to use the data for the
purposes for which it was originally collected by Us.
In the event that any of your data is to be transferred in such a manner, you will
not be contacted in advance and informed of the changes.
HOW CAN YOU CONTROL YOUR DATA?
When you submit information via Our Site, you may be given options to restrict
Our use of your data. We aim to give you strong controls on Our use of your data
(including the ability to opt-out of receiving emails from Us, which you may do by
unsubscribing using the links provided in Our emails).
You may also wish to sign up to one or more of the preference services operating
in the United States of America: The Telephone Preference Service (“the TPS”),
the Corporate Telephone Preference Service (“the CTPS”), and the Mailing
Preference Service (“the MPS”). These may help to prevent you receiving
unsolicited marketing. Please note, however, that these services will not prevent
you from receiving marketing communications that you have consented to
receiving.
YOUR RIGHT TO WITHHOLD INFORMATION AND YOUR RIGHT TO
WITHDRAW INFORMATION AFTER YOU HAVE GIVEN IT
You may access Our Site without providing any data at all. However, to download
free content or purchase content, materials and courses available on Our Site you
may be required to submit or allow for the collection of certain data.
You may restrict your internet browser’s use of Cookies.
You may withdraw your consent for Us to use your personal data at any time by
contacting Us, and We will delete Your data from Our systems. However, you
acknowledge this may limit Our ability to provide the best possible products and
services to you.
HOW CAN YOU ACCESS YOUR DATA?
You have the legal right to ask for a copy of any of your personal data held by Us
(where such data is held). Please contact Us for more details at
hello@howtohandletter.com.
WHAT COOKIES DO WE USE AND WHAT FOR?
Our Site may place and access certain first party Cookies on your computer or
device. First party Cookies are those placed directly by Us and are used only by
Us. We use Cookies to facilitate and improve your experience of Our Site and to
provide and improve Our products and services.
By using Our Site you may also receive certain third party Cookies on your
computer or device. Third party Cookies are those placed by websites, services,
and/or parties other than Us. We use third party Cookies on Our Site.
All Cookies used by and on Our Site are used in accordance with current English
and EU Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop
up bar requesting your consent to set those Cookies. By giving your consent to
the placing of Cookies you are enabling Us to provide the best possible
experience and service to you. You may, if you wish, deny consent to the placing
of Cookies; however certain features of Our Site may not function fully or as
intended.
Certain features of Our Site depend on Cookies to function. United States of
America and EU Cookie Law deems these Cookies to be “strictly necessary”.
Your consent will not be sought to place these Cookies. You may still block these
Cookies by changing your internet browser’s settings, but please be aware that
Our Site may not work as intended if you do so.
Our Site uses analytics services. Website analytics refers to a set of tools used to
collect and analyze usage statistics, enabling Us to better understand how people
use Our Site. This, in turn, enables Us to improve Our Site and the products and
services offered through it. You do not have to allow Us to use these Cookies, as
detailed below, however while Our use of them does not pose any risk to your
privacy or your safe use of Our Site, it does enable Us to continually improve Our
Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required
information. Certain Cookies may be placed immediately when you first visit Our
Site and it may not be possible for Us to obtain your prior consent.
You can choose to enable or disable Cookies in your internet browser. Most
internet browsers also enable you to choose whether you wish to disable all
cookies or only third party cookies. By default, most internet browsers accept
Cookies but this can be changed. For further details, please consult the help
menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies at any time however you may lose any
information that enables you to access Our Site more quickly and efficiently
including, but not limited to, login and personalization settings.
It is recommended that you keep your internet browser and operating system up-
to-date and that you consult the help and guidance provided by the developer of
your internet browser and manufacturer of your computer or device if you are
unsure about adjusting your privacy settings.
VIEWING BY OTHERS
Note that whenever you voluntarily make your Personal Data available for viewing
by others online through this Website or its content, it may be seen, collected and
used by others, and therefore, We cannot be responsible for any unauthorized or
improper use of the information that you voluntarily share (i.e., sharing a comment on a blog post, posting in a Facebook group that We manage, commenting on Our Facebook page, etc.).
PASSWORDS
If you are a student of Our online classes, you created a username and password
on the course platform We use to host Our classes: Teachable. Teachable is a
third-party website in which We have limited control over the data collected from
you upon signing up. You are responsible for maintaining the confidentiality of the
username and password, and you are responsible for all activities, whether by
you or by others, that occur under your username or password and within your
Teachable account. We cannot and will not be liable for any loss or damage
arising from your failure to protect your username, password or account
information on Teachable. If you share your username or password with others,
they may be able to obtain access to your Personal Data at your own risk. That
being said, Teachable is a reputable website that We have entrusted Our
personal data with as an online educator.
You agree to notify Teachable immediately of any unauthorized or improper use
of your username or password or any other breach of security. To help protect
against unauthorized or improper use, make sure that you log out at the end of
each session requiring your username and password.
THIRD PARTY WEBSITES
We will link to other websites on Our Website if we believe they provide helpful
information that will enrich your experience, or the content linked is relevant to
a/the blog post, question, comment, etc. We have no responsibility or liability for
the content and activities of any other individual, company or entity whose
website or materials may be linked to Our Website or its content, and thus We
cannot be held liable for the privacy of the information on their website or that you
voluntarily share with their website. Please review their privacy policies for
guidelines as to how they respectively store, use and protect the privacy of your
Personal Data.
SUMMARY OF YOUR RIGHTS UNDER GDPR
Under the GDPR, you have:
- The right to request access to, deletion of or correction of, your personal data held by Us;
- The right to complain to a supervisory authority;
- The right to be informed of what data processing is taking place;
- The right to restrict processing;
- The right to data portability;
- The right to object to processing of your personal data;
- Rights with respect to automated decision-making and profiling
- To enforce any of the foregoing rights or if you have any other questions
about Our Site or this Privacy Policy, please contact Us by email at
hello@howtohandletter.com.
AUTOMATED DECISION-MAKING AND PROFILING
In the event that We use personal data for the purposes of automated decision-
making and those decisions have a legal (or similarly significant effect) on You,
You have the right to challenge to such decisions under GDPR, requesting human
intervention, expressing their own point of view, and obtaining an explanation of
the decision from Us.
The right described above does not apply in the following circumstances:
- The decision is necessary for the entry into, or performance of, a contract
between the You and Us; - The decision is authorized by law; or
- You have given your explicit consent.
- Where we use your personal data for profiling purposes, the following shall
apply: - Clear information explaining the profiling will be provided, including the
significance of the likely consequences; - Appropriate mathematical or statistical procedures will be used;
- Technical and organizational measures necessary to minimize the risk of
error and to enable such errors to be easily corrected shall be
implemented; and - All personal data processed for profiling purposes shall be secured in order
to prevent discriminatory effects arising out of profiling.
DISPUTE RESOLUTION
You agree to notify Us of any concerns or issues, and to give Us an opportunity to
resolve those concerns or issues. If you and Our Company cannot find a
resolution to a dispute or potential claim by means of good-faith negotiation, then
you explicitly agree to make a reasonable attempt to resolve any such dispute
through Alternative Dispute Resolution or Mediation before filing a civil cause of
action.
Non-Disparagement. If you are found to be slandering, libeling or otherwise
disparaging Our Company, Course(s) or related materials, you will be immediately
removed from the Course(s) and any related communications. We reserve the right to file a civil claim of action against you for any such damaging actions you
take that materially harm Our Company.
CONTACTING YOU
We may contact you with information that you provide to Us based on these lawful
grounds for processing:
- Consent. We may contact you if you give Us your clear, unambiguous,
affirmative consent to contact you. - Contract. We will contact you under Our contractual obligation to deliver
goods or services you purchase from Us. - Legitimate Interest. We may contact you if we feel you have a legitimate
interest in hearing from Us. For example, if you sign up for a webinar, We
may send you marketing emails based on the content of that webinar. You
will always have the option to opt out of any of Our emails.
CONTACTING US
If you have any questions about Our Site or this Privacy Policy, please contact Us
by email at hello@howtohandletter.com. Please ensure that your query is clear,
particularly if it is a request for information about the data We hold about you.
CHANGES TO OUR PRIVACY POLICY
We may change this Privacy Policy as we may deem necessary from time to time,
or as may be required by law. Any changes will be immediately posted on Our
Site and you will be deemed to have accepted the terms of the Privacy Policy on
your first use of Our Site following the alterations. We recommend that you check
this page regularly to keep up-to-date.
Use of any personal information or contribution that you provide to Us, or which is
collected by Us on or through Our Website or its content is governed by this
Privacy Policy. By using Our Website or its content, you consent to this Privacy
Policy, whether or not you have read it. If you read this Privacy Policy and do not
agree with the terms listed, please do not use this Website in any way.
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