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.