Privacy Policy

I am concerned about online privacy. I recognize that it is not a “nice to have” extra, or something to get around, but necessary. I believe that people have a right to keep their inner lives actually private, and know that a great deal of our online behaviour is being mined to figure out things that we don’t necessarily even know about ourselves yet.

(For a 12-minute presentation I did on the importance of privacy and online security, you can check here.)

At the same time, some of these marketing technologies are vitally important to the success of tiny startup businesses, and I have implemented some of the most common ones.

I have an official policy (down below) drafted using an online service, but it is all that barely comprehensible legalese that is more about protecting my butt than actually telling you what is going on. In more clear terms, here’s what I’ve got:

1. Website
This website is built using WordPress.

I host my site at a company that keeps its WordPress installation and the servers up to date with security patches. The specific plugins and themes that I’m using may change, but I always have security and privacy concerns at the top of my list when I make any changes or additions.

At the moment I do not collect any personally identifiable information. If I do start doing so, I would like you to know that I believe in the importance of people being able to control what information is left behind in their traces, so anything I implement will include things like “being able to delete stuff for real.” (This has been required by European law since May 25, 2018, so I was ahead of the curve! I also think that all of us, anywhere, should be able to count on that.) Also, any sales I make would be stored in a secure server through a payment gateway, not on my own servers.

2. Products Page

My products subdomain is hosted at MemberVault. I do have personally identifiable information stored there, because it is necessary to track your progress through courses, which are accessed using an email address. I’m pretty sure you have encountered this before. I export the email addresses to my mailing list, because MemberVault has no email service, and I would not otherwise be able to get in touch with you. Even if you don’t give me permission to send you marketing email, I still need to store your address in my mailing software to be able to send you receipts, updates on your products, and (for example) reminders to move through multi-day courses.

3. Mailing List

My mailing list is hosted at MailerLite, and if you sign up for it, all appropriate features (like security and being able to unsubscribe) will be provided through their service.

A couple of things about mailing lists: We know a lot about what you are doing with our emails. We know if you (specifically) have opened particular emails, whether/what links you have clicked on, which wording was on the page you signed up from… things like that. Everybody who has an email provider worth their salt has access to this sort of functionality. They may not know how to use it, but they could. This means that the way you interact with the emails may change what I send you. (This is also how you get those eerie emails when you click on a link to a product but don’t buy the thing. I haven’t done that, but I’ve seen it done.)

I will not give anybody else access to my mailing list, nor will I use it for anything other than emailing you. (I will not, for example, give it to any other social network to connect with you there.)

If I change email providers but keep the same business, I will take the mailing list with me. In that case, I will delete it from the original mail provider. If I change businesses substantially (more than just changing the name of the website etc.) I will let you know, and may give you the option to join the new mailing list, but I will not just take the existing list to the new business.

I would like to ask for some grace here: Maintaining a mailing list has a lot of moving parts, and I might mistakenly send you an email you didn’t expect. If that happens, please be so kind as to unsubscribe rather than flagging it as Spam. Spam is not just something you don’t like from somebody you gave your address to… It’s an intentional and ongoing abuse of the email system, and the penalties to a business can be huge.

3. Facebook

I am not currently using the FB tracking pixel. I really hate it as a technology. I think it’s creepy and should be illegal, but it also puts me at an enormous disadvantage as a micro business.

This is a technology that links this website back to FB for an advertising tactic called “retargeting.” This allows FB (but not me) to know if you have visited this website. If I were to use is, FB could use that information to show you ads from me, but I would still not know who you are.

If you don’t want this to work, you can use an adblocker or turn off the cookies in your browser. You can also delete them from your browsing history. Here is Facebook’s Cookie Policy.

If you do see an ad from me on FB, it is of a more generic kind.

I will not know if FB targets you with an ad from me: that’s done by algorithms that are outside of my control. I am able to target (for example) 45-year-old women with purple hair* who live in Oklahoma, but I will not know who the specific women are who fit that profile. This also has nothing to do with the link back from this website.

(* Actually, I don’t think FB knows what colour your hair is. But I could say, “people who like [a page that features rainbow hair dyes].”)

If you want a lot more information on how cookies work, there is a good explainer here: https://www.youtube.com/watch?v=vxoZSEbrX5A

4. Google
I am not currently using Google Analytics*, or Google Ads, so if there are ads showing up around my site, that is from your browser and your own search history, not anything to do with this website.

If either of the previous sections gave you pause, you might want to do some research on “remarketing” or “retargeting” to find out why/how “they” show you things you were just looking at.

* This is likely to change since I can’t currently tell how many people are reading my posts.

I will be making some changes to this document over the next couple of weeks in anticipation of GDPR. They will make it more private, not less.


Now for the long legal version designed to reassure you that we take this seriously, without any risk of you actually reading it:

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

What personal information do we collect from the people that visit our blog, website or app?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.

When do we collect information?

We collect information from you when you register on our site, fill out a form or enter information on our site.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
To send periodic emails regarding your order or other products and services.

How do we protect your information?
I use a number of services that are top of the line for their industry. My payments all go through an authorized payment processor and I never keep any information about credit cards.

Do we use ‘cookies’?

We may send cookies to your computer in order to uniquely identify your browser and improve the quality of our service. The termcookiesrefers to small pieces of information that a website sends to your computers hard drive while you are viewing the Site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). You have the ability to accept or decline cookies using your web browser settings. If you choose to disable cookies, some areas of the Site may not work properly or at all.

We use cookies to:
Keep track of advertisements.
Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

Nature has an excellent description of Cookies in their privacy policy, if you want more information.

Third-party disclosure
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third-party links
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We have not enabled Google AdSense on our site but we may do so in the future.
California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
You will be notified of any Privacy Policy changes:
On our Privacy Policy Page
Can change your personal information:
By emailing us
How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we allow third-party behavioral tracking

COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.

Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions
Process orders and to send information and updates pertaining to orders.
Send you additional information related to your product and/or service
Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
Not use false or misleading subjects or email addresses.
Identify the message as an advertisement in some reasonable way.
Include the physical address of our business or site headquarters.
Monitor third-party email marketing services for compliance, if one is used.
Honor opt-out/unsubscribe requests quickly.
Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at

Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
Contacting Us
If you have any questions regarding this privacy policy, you may contact me using the information below.
info@seonaidlee.com
650 Hillside Rd
Albert Bridge, NS B1K 3H8
Canada
Last Edited on April 11, 2018