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Privacy Policy
SUSAN O'CONNOR, INC.
PRIVACY NOTICE
Introduction.
Website Owner.
Susan O'Connor, Inc. ("Company") is the owner of this web site ("Company Website"). Company can be contacted by e-mail at susan@susanoconnorwriter.com This online privacy notice discloses Company information practices for this Company Website, including what type of personal identifiable information is requested in order to make a purchase, how the information is used, and with whom the information is shared.
Website Visits.
Company collects certain information from Company Website visitors. This includes information collected by our third party Website provider to host the Website, which can be viewed here: https://support.strikingly.com/hc/en-us/articles/214364818-Strikingly-s-Privacy-Policy
Website Transactions.
At times, Company will need personal information regarding a customer or a prospect. For example, to process an order or provide a service requested by a customer or prospect, such as a sign-up for a writing seminar, master class, or other product, Company may need to know a customer's full name, billing information (such as an address), e-mail address and credit card details. It is Company's intent to inform you before the Company collects personal information, such as your name and/or address, on the Internet. If you tell us that you do not wish to have this information used as a basis for further contact with you, the Company will respect your wishes, but this will also limit the products and services which may be available to you.
GDPR.
In addition, when Company does collect personal information, we do so while mindful that the collection of such information is subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and that Company is responsible as “controller” of that personal information for the purposes of those laws.
Categories of Personal Information That May Be Collected.
Identifying Information.
In order to make a purchase and/or access designated subscriber services and/or restricted areas within the Company Website, Company will request a user to provide certain personal identifying information. Company may request additional information necessary to establish and maintain the customer's account, and will advise customers of the purpose and use of such information at the time of collection.
Service Quality Monitoring.
Some Web site transactions may require a customer to telephone the Company, or Company to call the customer. Company will not contact you by telephone without your prior consent, except to confirm an order placed online and/or to inform a customer of the status of such order. Customer should be aware that it is the Company's practice to monitor, and in some cases record such calls for staff training or quality assurance purposes.
Information from Children.
Company does not collect or maintain information from users actually known to be under the age of 13, and no part of Company's Web sites are structured to attract anyone under the age of 13.
Lost or Stolen Information.
Help keep your personal information accurate. If a customer's personal information has changed, please e-mail the new information to Company at the e-mail address shown in Paragraph 1(a). If a customer would like to review the personal information Company has in its files regarding the customer, e-mail your request to Company together with the description of a recent purchase and Company will voluntarily provide this information to you.
Company Communications; Third Party Services.
If customer participates in a Company chat room, discussion forum, posts messages to an Company bulletin board, or participates in seminar dialogue and interaction with Company and other of Company’s customers, customer should be aware that the information disclosed and shared will be broadly available to other persons, both inside of and/or outside Company, who have access to that chat room, forum or bulletin board, or who are present at such seminar(s). Some individual Company chat rooms, forums or bulletin boards, and seminars, have additional rules and conditions regarding participation. Also, participant's expressed opinion is his or her own and should not be considered as reflecting the opinion of Company. Please review the privacy policies of third party providers of such services, including Slack, Voicethread, and Articy in order to determine the information gathered by such providers for your use of these tools.
Links to Other Web Sites.
Company Website may contain links to other web sites. Company is not responsible for the privacy practices or the content of those other Web sites.
Purposes of Collection; Uses Made of the Information; How and Why We Use
Your Personal Information.
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
· To comply with our legal and regulatory obligations;
· For the performance of our contract with you or to take steps at your request before entering into a contract;
· For our legitimate interests or those of a third party; or
· Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for
To provide products and services to you (limited uses identified)
Our reasons
For the performance of our contract(s) with you or to take steps at your request before entering into a contract, such as writing workshops, seminars, newsletters, or otherwise. Without customer's prior consent, Company will not use your personal identifiable information for any purpose other than that for which it is submitted. Company uses personal identifiable information to reply to inquiries, handle complaints, provide operational notices and in program record-keeping. Company also processes billing and business requests related to Company Web Site and product/service participation.
What we use your personal information for
To prevent and detect fraud against you or Company
Our reasons
For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
What we use your personal information for
Ensuring business policies are adhered to, e.g. policies covering security and internet use
Our reasons
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
What we use your personal information for
Operational reasons, such as improving efficiency, training and quality control
Our reasons
For our legitimate interests or those of a third party
What we use your personal information for
Ensuring the confidentiality of commercially sensitive information
Our reasons
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
What we use your personal information for
Statistical analysis to help us manage our business, e.g. in relation to performance, subscriber/licensee base, product range or other efficiency measures
Our reasons
For our legitimate interests or those of a third party
What we use your personal information for
Preventing unauthorized access and modifications to systems
Our reasons
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
What we use your personal information for
Updating and enhancing customer records
Our reasons
For the performance of our contract(s) with you or to take steps at your request before entering into a contract. Company stores and retains the information entered on the Website. Stored information is used by Company to support customer interaction with the Company Website; to deliver customer purchases; and/or to contact customer about other Company services and products.
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our subscribers and customer(s) about existing Offerings, industry updates and news, and new products and services
What we use your personal information for
Marketing our services and those of selected third parties to: existing and former subscribers and customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.
Our reasons
For our legitimate interests or those of a third party, i.e. to promote our products to existing and former subscribers and customers. Unless customer opts out, Company reserves the right to provide customer with information about Company's Web Site, Company products and services, and related information in which customer has indicated an interest, whether by subscribing to a blog or newsletter, signing up for a product or service, or otherwise indicating your interest in the products and services of Company. The information you provide to the Company Website may also be collected, used, analyzed and/or processed by Company, or selected third parties on Company's behalf, for marketing and other business purposes of Company. Company will never sell your information to a third party without your consent. Some companies that help Company deliver interactive on-line advertising, such as banner ads, may collect and use information about Company's customers to help Company better understand the types of advertising or promotions that are most appealing to Company's customers. After it is collected the information is aggregated so it is not identifiable to a specific individual. If, however, you would prefer that these companies not collect such information, please notify Company and we will respect your request.
What we use your personal information for
External audits, investigations, and quality checks
Our reasons
For our legitimate interests or a those of a third party
To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Disclosure of the Information.
Within Corporate Organization.
Company may share your personal information within the Company corporate organization, and may transfer the information to countries in the world where Company conducts business. Some countries may provide less legal protection for customer personal information.
Mergers and Acquisitions.
Circumstances may arise where for business reasons, Company decides to sell, buy, merge or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the disclosure of personal identifying information to prospective or actual purchasers, and/or receiving such information from sellers. It is Company's practice to seek appropriate protection for information in these types of transactions.
Agents.
Company employs or engages other companies and individuals to perform business functions on behalf of Company. These persons are provided with personal identifying information required to perform their functions, but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to, fulfilling orders, delivering services purchased by Customers, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments and providing customer services.
Affiliated Businesses.
At times, Company may work closely with affiliated businesses operating website stores, providing services or selling products on each other's Web sites. These businesses identify themselves to customers. Customer information related to a transaction with an affiliated business is shared with that affiliated business for purposes of completing the transaction.
Marketing Analysis by Third Parties.
Company reserves the right to disclose to third parties personal information about customers for marketing analysis; however, if any information is so disclosed it will be in the form of anonymized aggregate data that does not describe or identify an individual customer.
Disclosure to Governmental Authorities.
Company releases personal identifying information when Company believes release is appropriate to comply with law, to enforce Company agreements, or to protect the rights, property or safety of Company customers. Company may also release such information in an exchange of information with other companies and/or organizations for the purposes of fraud protection and credit risk reduction.
No Further Sale of Customer Information.
Except as provided herein, Company does not sell Customer information to third parties.
Use of Computer Tracking Technologies.
Company’s third party Website provider collects certain information as the host of Company’s Website, which can be viewed here. In addition, please be aware of the following:
No Tracking of Personal Information.
Except as provided above, Company's Website(s) are not set up to track, collect or distribute personal information not entered by visitors. Through Website access logs, Company may collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provides better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties.
Use of Cookies.
Company, or its third party vendors, collects non-identifiable and personal information through the use of various technologies, including "cookies." A cookie is an alphanumeric identifier that a Web site can transfer to customer's hard drive through customer's browser. The cookie is then stored on customer's computer as an anonymous tag that identifies the customer's computer, but not the customer. Cookies may be sent by Company or its third party vendors. Customer can set its browser to notify customer before a cookie is received, giving an opportunity to decide whether to accept the cookie. Customer may also set its browser to turn off cookies; however, some Websites may not then work properly.
Use of Web Beacon Technologies.
Company may also use Web beacon or other technologies to better tailor its Web site(s) to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Web site, a non-identifiable notice of that visit is generated which may be processed by Company or by its suppliers. Web beacons usually work in conjunction with cookies. If customer does not want cookie information to be associated with customer's visits to these pages, customer can set its browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
Collection of Non-Identifiable Information.
Company may collect non-identifiable information from user visits to the Company Website(s) in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on Company Website(s); Website and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." Company or its contractors may use this data to analyze trends and statistics.
Collection of Personal Information.
As noted above, Company collects personal identifying information from customer during a transaction. Company may extract some personally identifying information about that transaction in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help Company understand trends and patterns. This information is not reviewed at an individual level or sold to third parties.
Information Security; Where Information is Held; Rights Under GDPR
Commitment to Online Security.
Company intends to protect customer personal information and to maintain its quality. To achieve information security and quality, Company implements appropriate measures and processes, such as using encryption when transmitting certain sensitive information, and utilizes reasonable measures for the protection of its systems and data.
No Liability for Acts of Third Parties.
Company will exercise all reasonable efforts to safeguard the confidentiality of customer personal information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, Company shall not be liable for unauthorized disclosure of personal information due to no fault of Company including, but not limited to, errors in transmission and unauthorized acts of Company staff and third parties.
Where Information is Held.
Information may be held at our offices and those of our service providers, representatives and agents as described above. Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”
Transferring Your Personal Information Out of the EEA.
To deliver services to you it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.: (i) With your and our service providers located outside the EEA, including the vendors as provided herein; (ii) If you are based outside the EEA; or; (iii) Where there is another international dimension to the services we are providing. These transfers are subject to special rules under European and UK data protection law. The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: the USA and Canada. For any non-EEA countries that do not have the same data protection laws as the United Kingdom and EEA we will ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses or if you would like further information on international transfers of data, please contact our Data Protection Officer (see “How To Contact Us” below).
Your Rights Under GDPR (if you are an EU Data Subject):
Right to Access
The right to be provided with a copy of your personal information (the right of access)
Right to Rectification
The right to require us to correct any mistakes in your personal information
Right to be Forgotten
The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object
The right to object: (i) at any time to your personal information being processed for direct marketing (including profiling); (ii) in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
Privacy Policy Changes and Opt-Out Rights.
Changes to Privacy Policy.
This privacy notice was last updated on July 23, 2020. Company reserves the right to update its privacy policy statement at any time. A notice of such change will be posted on the Company Website home page for ten (10) days prior to the implementation of such change.
Opt-Out Right.
Customer and prospective customer has the right at any time to cease permitting personal information to be collected, used or disclosed by Company and/or by any third parties with whom Company has shared and/or transferred such personal information. Right of cancellation may be exercised by contacting Company via e-mail at susan@susanoconnorwriter.coml. After processing the cancellation, Company will delete customer or prospective customer's personal information from its database, except as required for recordkeeping related to customer’s purchases and communications with Company.
Access Rights to Data.
Information Maintained by Company.
Upon customer's request, Company will provide a reasonable description of customer's personally identifiable information that Company maintains in its data bank. Company reserves the right in any such instance to first verify the identity of the requestor. Company can be contacted by e-mail at susan@susanoconnorwriter.com.
Corrections and Changes to Personal Information.
Help Company to keep customer personal information accurate. If customer's personal information changes, or if customer notes an error upon review of customer information that Company has on file, please promptly e-mail Company at susan@susanoconnorwriter.com and provide the new or correct information.
Accountability; Exercising Rights
Questions, Problems and Complaints; Exercising Rights.
If you have a question about this policy statement, or a complaint about Company compliance with this privacy policy, or if you would like to exercise any of your rights as described in this Privacy Policy, you may contact Company by e-mail at susan@susanoconnorwriter.com.
When contacting us, please provide us with:
· Enough information to identify you (e.g., your full name and address;
· Secure proof of your identity and address (e.g., an encrypted copy of your driving license or passport and a recent utility or credit card bill); and
· A description of what right you want to exercise and the information to which your request relates.
We are not obligated to act on your request if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. For your own security, we will investigate your identity before providing any information. Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Other Terms of Use/Service. If customer chooses to enter into a purchase or to subscribe to Company's services which references this Privacy Policy, customer's action is hereby deemed acceptance of Company practices described in this policy statement and the terms herein are incorporated by reference into the terms of service or other agreement governing such purchase or subscription. Any dispute over privacy between customer and Company is subject to the provisions of this notice and to Company's Terms of Use Agreement which is hereby incorporated herein and which can be read at http://www.susanoconnorwriter.com?open=terms-and-conditions.