We do not sell any of your personal data to any third party. You always have the right to unsubscribe at any time.
If you have any questions, please reach out to us at contact@SpencerWhitePublishing.com
Team Spencer White Publishing
Updated March 2020
Your provision of your personal information to us is completely voluntary. “Personal information or data” is information that can specifically identify you. We do not collect personal information unless you submit that information to us. Categories of personal information we may collect include:
- Identity Data, which includes name or other similar identifiers.
- Contact Data, which includes address, email address and telephone numbers.
Additionally, we may also collect certain others types of information that, along with Identity Data and Contact Data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:
- Financial Data, which includes credit card, debit card or other payment card details.
- Transaction Data, which includes details about payments to and from you.
- Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information.
- Profile Data, which includes your username and password, avatar (if you upload one) and other info you share with us on our Website.
- Usage Data, which includes information about how you use our Website and advertising we serve on those sites.
- Marketing and Communications Data, which includes your preferences in receiving marketing from us.
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your information by registering or contacting us. This includes information you provide when you:
- create an account on our website;
- subscribe to our service or publications;
- purchase product(s) on our website(s)
- request marketing to be sent to you; or
- give us feedback.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data and Usage Data about you. Some of the ways in which we or our website may collect are further described below:
Cookies and other technologies: We use the following cookies to help us better serve you: (i) Strictly necessary / technical cookies that are required for the operation of our website, including log-in, shopping cart and e-billing. (ii) Analytical / performance cookies to see how users interact with our website so that we may improve functionality. (iii) Functional cookies to recognize you when you return and to personalize content. (iv) Targeting cookies to tailor outreach to you based on how you interact with our website.
Clickstream Data: This data helps us identify the types of computers and browsing software being used and where our website traffic is coming from which helps us to create a better browsing experience. This is collected as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website, how visitors navigate throughout the Website and how we may tailor our website to better meet the needs of visitors. This information often will be used to improve our website and our services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any personal information.
Our Limited License to You
The Site is provided solely for your personal noncommercial use. You may, from time to time, download and/or print copies of individual pages of the Site for your personal, non-commercial use, provided that you keep intact any copyright and other proprietary notices. You may share information found on our site for personal, noncommercial purposes.
Your License to Us
By posting or submitting any material (including, without limitation, comments, blog entries, Facebook postings, photos and videos) to us via the Site, internet groups, social media venues, or to any of our staff via email, text or otherwise, you are representing: (i) that you are the owner of the material, or are making your posting or submission with the express consent of the owner of the material; and (ii) that you are thirteen years of age or older. In addition, when you submit, email, text or deliver or post any material, you are granting us, and anyone authorized by us, a royalty-free, perpetual, irrevocable, non-exclusive, unrestricted, worldwide license to use, copy, modify, transmit, sell, exploit, create derivative works from, distribute, and/or publicly perform or display such material, in whole or in part, in any manner or medium, now known or hereafter developed, for any purpose. The foregoing grant shall include the right to exploit any proprietary rights in such posting or submission, including, but not limited to, rights under copyright, trademark, service mark or patent laws under any relevant jurisdiction. Also, in connection with the exercise of such rights, you grant us, and anyone authorized by us, the right to identify you as the author of any of your postings or submissions by name, email address or screen name, as we deem appropriate. You acknowledge that we have the right but not the obligation to use and display any postings or contributions of any kind and that we may elect to cease the use and display of any such materials (or any portion thereof), at any time for any reason whatsoever.
Information Use And Sharing
Subject to the section titled “Additional EU Disclosures”, we use information held about you to perform our services and for other purposes outlined below. Specifically, we use your information for a variety of purposes:
- Where we need to perform a contract we are about to enter into or have entered into with you.
- To perform specific services that you have requested.
- To respond to your direct inquiries.
- Where it is necessary for our legitimate business interests.
- To send you marketing materials (see below).
- Where we need to comply with a legal or regulatory obligation.
Use of Your Personal Data For Marketing Purposes
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- If you have requested information from us or used our services and you have not opted out of receiving marketing, you may receive marketing from us about promotions such as competitions, prize drawings and free give-aways, and information on a product or service we think you may find helpful. We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We do not share your personal data with any company outside our company for marketing purposes.
To see how you can opt out of marketing communications, please see the section titled “Opt-Out” below and found at the bottom of all of our email communications.
Legitimate Business Interests
Subject to the section titled “Additional EU Disclosures”, we may share the information we collect about you with certain third parties for legitimate business purposes in the following ways:
To use certain services on our website, payment card information may be requested. We may ask you for credit card, debit card, or other payment information. By submitting your payment information through our websites, to the extent permitted by applicable law, you expressly consent to the sharing of your information with our third-party payment processors, and other third-party service providers.
To third parties if we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them, if we are part of a bankruptcy proceeding or other change in control.
Third parties to whom we need to share your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the website.
Third Party Links And Social Networking Services
Our website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly. By using such services you assume the risk that the information provided by you may be viewed and used by third parties.
We have put in place appropriate security measures to prevent information about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed; however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have put in place procedures to deal with any suspected data breach that will affect you and will notify you and any applicable regulator of a breach where we are legally required to do so. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
Opting Out Of Messages From Us
To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at contact@SpencerWhitePublishing.com. If you do not want your personal information or personal data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to contact@SpencerWhitePublishing.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our website may no longer be available to you.
Opting Out Of Cookies
If you want to stop or restrict the placement of cookies or remove any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge.
If you are a California resident this section applies to you. Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personally identifiable information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, contact us at contact@SpencerWhitePublishing.com. If you do not want your personally identifying information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at contact@SpencerWhitePublishing.com.
Enforcement and Disclosure of Information
SpencerWhitePublishing.com further reserves the right to disclose any information about you (including your identity) necessary for any investigation of any complaint related to your use of the Site and/or to bring legal action against you for damages caused to SpencerWhitePublishing.com, and/or its customers by your violation of these Terms and Conditions. SpencerWhitePublishing.com further reserves the right to disclose any information about you necessary to comply with any applicable law, regulation, legal process or governmental request.
In the event SpencerWhitePublishing.com does take any legal action against you as a result of your violation of these Terms and Conditions, SpencerWhitePublishing.com is entitled to recover from you all reasonable attorneys’ fees and costs of such action, in addition to any other relief that may be granted.
In the event SpencerWhitePublishing.com does not strictly enforce one or more provisions of these Terms and Conditions, such action is not a waiver of that or any other provision of these Terms and Conditions against you or any other parties. Further, such conduct does not constitute a modification of any provision of these Terms and Conditions.
Additional EU Disclosures
OUR ROLE AS DATA CONTROLLER AND DATA PROCESSOR
SpencerWhitePublishing.com generally acts as the data controller of your information submitted through our website.
If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. Please see our contact details below in the section titled “Contact Us”. If you are situated in the EU and have a complaint, please contact our privacy manager at contact@SpencerWhitePublishing.com.
PROVISION OF PERSONAL DATA AND FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.<
LEGAL BASIS FOR OUR PROCESSING OF YOUR PERSONAL DATA
Below are the types of lawful basis that we will rely on to process your personal data:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at contact@SpencerWhitePublishing.com.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at contact@SpencerWhitePublishing.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
COLLECTION OF PERSONAL DATA FROM THIRD PARTY SOURCES
- We may also collect personal data about you from various third parties and public sources.
- For example, if you register for our services using Facebook, Twitter or other social media sites, we will collect your information from those social media sites.
As discussed above, we also obtain information through automated technologies (see section titled “Information Collection”)
- We may use autoresponders to communicate with you by e-mail. To protect your privacy, we use a verified opt-in system for such communications and you can always opt-out of such communications using the links contained in each autoresponder message. If you have difficulties opting out, you may contact us by sending an e-mail to contact@SpencerWhitePublishing.com.
We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- DoubleClick Platform integrations
- Google Analytics Demographics and Interest Reporting
By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Site, and match the right audience with the right advertising message.
We abide by Facebook’s Data Use Restrictions.
- Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
- We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
- We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
- We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.
We may display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at contact@SpencerWhitePublishing.com.
CHILDREN’S PRIVACY STATEMENT
This children’s privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information regarding their rights under federal law with respect to such information.
- This Site is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the Site. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the Site, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Site.
- Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we also do NOT knowingly distribute such information to third parties.
We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Site.
- Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we do NOT condition the participation of a child under thirteen in the Site’s online activities on providing personally identifiable information.
WITHDRAWING YOUR CONSENT
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at contact@SpencerWhitePublishing.com
RIGHTS OF EU DATA SUBJECTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
To exercise your rights, please contact us at contact@SpencerWhitePublishing.com
CROSS BORDER TRANSFERS
If you are situated in the EU, we will likely share your personal data within our group of companies or third parties service providers that are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Whenever we transfer your personal data out of the EEA, we will do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.