1. NOTICE CONCERNING CHILDREN.
(1) This Site is directed at adults, not children. We do not knowingly collect personally identifiable information from anyone under the age of 18. Any website “directed at children under 13” must undertake certain compliance steps pursuant to the Children’s Online Privacy Protection Act [15 U.S. Code § 6502] and COPPA Rule [16 CFR Part 312] and General Data Protection Regulation of the European Union [Article 8]. Please contact us immediately if you are a parent or guardian and have knowledge of a child under 13 or anyone under the age of 18 using the Site.
(2) California Minor Eraser Law. Should you post or forward content or data to use while you are under the age of 18, you have the right to request such data be removed. Contact us to make such a request. Please note the removal of any published data or content on the Site does not guarantee the removal of such content from the Internet as sites such as the Wayback Machine and Google create archival copies of the web that may be accessed at any time.
2. INFORMATION COLLECTED
A. PERSONAL DATA
(1) Information Collection: While using our Site, we may require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information:
- Contact Data (such as your name and e-mail address)
- Commercial Data for commercial projects (such as your name, email address, company name, and phone number)
- Financial Data (for purchase transactions including your name, delivery and home address [street, ZIP, City, State, Country], email address, and payment source)
- Survey Data (such as your name, email address, and preferences regarding style, format, subject matter and other attributes of our Products or Services)
(2) If you communicate with us by e-mail, submit comments, or otherwise contact us, any information provided in such communication may also be classified as Personal Information.
B. USAGE AND TRAFFIC DATA
(1) We automatically track and collect the following categories of information when you visit our Site: IP addresses, domain servers, types of computers accessing the Site, types of web browsers used to access the Site – collectively “Traffic Data” – but also the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data – collectively “Usage Data”. Usage and Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes and for helping us improve your experience when using the Site.
(2) Google Tracking: We use certain Google programs to help us analyze the traffic to this Site and improve our marketing efforts. Such programs may include, but are not limited to, Google Font, Google Analytics in general, and Google Analytics Demographics in particular that require Google to collect data via advertising cookies and identifiers. You may opt out of this tracking by visiting https://tools.google.com/dlpage/gaoptout/ or http://www.networkadvertising.org/choices/.
(3) Third Party Tracking. We allow additional third-party companies including, but not limited to, Facebook to collect certain anonymous information when you visit our website. These companies may use non-personally identifiable information (e.g. links you click versus those you don’t, the type of browser you use, etc.) during your visits to this Site and other websites to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie to collect this information. To learn more about this behavioral advertising practice visit the NAI at http://www.networkadvertising.org. To opt-out of this type of advertising, you can visit http://www.networkadvertising.org/choices/ which will automatically detect and opt-out of a majority of the tracking programs.
C. TRACKING & COOKIES DATA
(2) Do Not Track Signals: Certain states such as California require that we disclose whether we acknowledge “do not track” signals issued by browsers or privacy software. We do not respond to such signals at this time. However, we use MailChimp as our email newsletter service provider, and that company does acknowledge do not track signals.
- Facebook – [https://www.facebook.com/ads/website_custom_audiences/]
- Google – [http://www.google.com/settings/ads]
(5) Cookies used on our site:
3. PROCESSING OF PERSONAL DATA
A. GROUNDS FOR PROCESSING PERSONAL DATA
(1) Legitimate Interest: We are relying on the basis of legitimate interest for processing your Personal Data. We provide valuable information, products and services to people who are interested in the topics we cover. It is in our interest to maintain and grow our business while serving you with related and valuable information, products and services.
(2) Consent: We are relying on the basis of consent for processing your Personal Data. Please see below (D. GETTING CONSENT) to learn about the ways you can give consent. We consider your consent to be given when you use one of the ways described below.
B. PROVIDING CLARITY
(1) Whenever you have to enter Personal Data for processing on our Site we try to provide descriptive and informational text as clear as possible to help you understand how your data will be processed and what you can expect from the processing. If you have any questions please get in touch with us before you submit your data.
B. ASSUMING LEGITIMATE INTEREST
(1) We provide valuable and educational content based on specific topics and we offer our own products and services closely related to this content. We also provide valuable information about related products and services provided by third parties which are also closely related to our content. We are relying on legitimate interest when we provide all these types of information to you.
(2) When we offer you reports, documents, files, email series and other items of value which are offered for free, we are relying on legitimate interest to send you marketing or informational communications.
(3) We assume that you accept our basis of legitimate interest as long as you actively ask for or consume our information. If you no longer are interested you can always opt out of receiving information. In that case we don’t rely on legitimate interest any longer.
D. GETTING CONSENT
(1) OptIn-Forms: By clicking the Submit-Button of an OptIn-Form you are showing clear consent to have your Personal Data be processed in the way the text within or near the form describes.
(2) Contact Forms: By clicking the Submit-Button of a Contact-Form you are showing clear consent to have your Personal Data be processed in the way the text within or near the form describes.
(3) Checkboxes: By activating a checkbox within a form you are showing clear consent to have your Personal Data be processed in the way the text near the checkbox describes.
(4) Double OptIn: After submitting an OptIn-Form for the first time (“new subscriber”) we will send you a confirmation email with a link inside. By clicking this OptIn-Link you are showing clear consent to have your Personal Data be processed in the way the text within or near the form or within the confirmation email describes.
(5) Mixed Options: Please understand that the options (1)-(4) can also be used in combination.
4. USE OF INFORMATION COLLECTED
(1) General use of Information: We use your Personal Information to fill orders, communicate with you, and market to you as well as comply with various laws as detailed herein. Please read this secion carefully.
(2) Sharing Personal Information: We share certain categories of information we collect from you in the ways described in this Policy. We share Contact, Commercial and Financial Data with our business partners who assist us by performing core services (such as hosting, email sending, billing, and order fulfillment) related to our operation of the Site. If you do not want us to share your Personal Information with any third parties, please contact us upfront, but please understand that such a request will eliminate your ability to order Products or Services from the Site since we will be unable to process your order, eliminate your ability to receive content from us via Email or eliminate your ability to access parts of our Site declared as member areas.
(3) Use of Contact Data: We use your Contact and Commercial Data to provide you with administrative communications such as email messages confirming orders or providing customer support. We also use your Contact and Commercial Data to send you (a) educational or informational content, (b) occasional promotional or commercial content highlighting our or third-party products and services as well as (c) business developments. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
(4) Use of Usage, Tracking and Cookies Data: We use your Usage Data to provide and maintain our Site, Products and Services, monitor the usage of our Site and to detect, prevent and address technical issues. We also use these Data to gather analysis or valuable information so that we can improve our Site, Products and Services.
A. METHODS OF PROCESSING
(1) The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
(2) In some cases, the Data may be accessible to external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies, tax consultants, payment processors).
B. PLACE AND OWNERSHIP
(1) All information collected is processed at our operating office and in any other places where the parties involved in the processing are located.
(2) Please understand that in general your information is stored and processed on systems located in the USA.
(3) Owner and Data Controller of all information collected is Vahlbruch Media, LLC – Texas, USA. Contact for all Data related belongings is Heinz R. Vahlbruch.
(1) We will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
(2) We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
(3) We will maintain your information and payment history for bookkeeping and tax reporting purposes.
D. SHARING PERSONAL INFORMATION
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how this Site is used.
These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
(1) Google Analytics
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Sending Messages and Managing Contacts
This type of service makes it possible to manage a database of email contacts to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: email address, name.
We may provide paid products and/or services within the Site. In that case, we use third-party services for payment processing (e.g. payment processors).
Stripe is a payment processing service provided by Stripe Inc.
Personal Data collected: name, billing address (street, ZIP, city, state, country), email address, payment method, credit card information.
Paypal is a payment processing service provided by PayPal Holdings, Inc.
Personal Data collected: name, billing address (street, ZIP, city, state, country), email address, payment method, credit card information.
5. INFORMATION SECURITY
(1) Security of Personal Information: The security of your data is important to us, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee absolute security.
(2) Confidentiality: Except as otherwise provided in this Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce the legal documents applicable to the Site.
(3) Lost or Stolen Information: You must promptly notify us if your payment information is lost, stolen, or used without permission so that we may take preventive measures to avoid the compromise of Site security if any are required.
(4) Site Security: The Site has reasonable security measures in place including Secure Sockets Layer technology as well as other confidential software and protocols to secure the data we obtain from you, but we make no assurances about our ability to prevent any such loss to you or any third party arising out of any such loss, misuse, or alteration. We do not store your Financial Data on the Site. Should a breach event occur, we will follow all relevant notice requirements dictated by applicable law.
6. GENERAL DATA PROTECTION REGULATION (GDPR)
A. LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GDPR
If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Policy depends on the Personal Data we collect and the specific context in which we collect it.
We may process your Personal Data because:
- We are doing business with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- For payment processing purposes
- To comply with the law
B. YOUR DATA PROTECTION RIGHTS UNDER GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights:
- The right to access, update or to delete the information we have on you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
C. EXERCISE YOUR RIGHTS UNDER GDPR
(1) To excerise any of your rights under GDPR please please contact us using the Contact page or by sending an email to office [-at-] vahlbruch.net.
(2) Please understand that we may ask you to verify your identity before responding to such requests.
7. ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
A. SALE OF INFORMATION
(1) Should we decide to sell all or part of the Site, our business, or our parent company be sold at some point in the future, your Personal Information will be included as an asset in the transfer of the business to the new owner.
8. AREAS BEYOND OUR CONTROL
(1) Public Information: We allow you to post content on the Site such as blog comments. Please keep in mind that the information you provide may be viewed by the general public and is, in no way, confidential. Do not post anything you prefer to keep private.
(2) Third Party Websites: The Site contains links to other websites. We have no control over the terms and privacy policies of said sites. Please make sure to view the policies of those sites before proceeding.
9. CHANGES TO THIS POLICY
(1) We may update this Policy at any time and will notify you of any changes by posting the new Policy on this page. We recommend that you should check this page often. Changes to this Policy are effective when they are posted on this page. You may reject the update by discontinuing your use of the Site.
10. CONTACT INFORMATION
(1) If you have any questions about this Policy or our practices related to this Site, please contact us using the Contact page or by sending an email to office [-at-] vahlbruch.net.