Effective as of January 1, 2020
In this Policy, “include” or “including” means “including but not limited to,” and any examples given are for illustrative purposes.
The Company respectsYour privacy and We are committed to protecting it through our compliance with this Policy. We want You to rest assured that the way in which We process data is lawful, fair and transparent.
This Policy Pertains to Information We Collect From You
This Policy describes the types of information We may collect from You or that You may provide when You visit the Website and Our practices for collecting, using, maintaining, protecting, and disclosing that information. The data controller for this website is Karen Donaldson of UpSpiral LLC. Contact Karen Donaldson at firstname.lastname@example.org or via phone at (929) 444-2993.
This Policy applies to information we collect:
- On this Website.
- In email, text, and other electronic messages between You and the Company, including through this Website.
- Through mobile and desktop applications You download from this Website, if any, which provide dedicated non-browser-based interaction between You and this Website.
This Policy does not apply to information collected by:
- Us, offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
You Agree You Are Over Age 18 or You Will Not Use The Website
Our Website is not intended for those under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If You are under 18, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about Yourself to Us, including your name, address, telephone number, email address, or any screen name or user name You may use. If You believe We might have any information from or about a child under 13, please contact us at email@example.com.
Information We Collect About You and How We Collect It
“Personal Information” is defined by N.Y. Gen. Bus. Law § 899-aaas “information concerning a natural person which, because of name, number, personal mark, or other identifier, can be used to identify such natural person” (“Personal Information”). By utilizing the Website and voluntarily providing Personal Information, You hereby consent to Our use of such Personal Information, as described herein.
Generally, we collect, process, and store Personal Information provided by Youthrough Your voluntary use of the Website. By providing any information to Us or through this Website, or via any other means, You give Us permission to collect, process, and store all data related thereto. We may also process Personal Information on other bases permitted by the European Union’s General Data Protection Regulation (“GDPR”) and applicable NY State and US federal laws, such as when data processing is necessary for Us to comply with Our legal obligations. By providing such information, You agree that We may collect, process, and store information You provide when You are introduced to Us, when We meet You in person, or when We are in contact with You via phone, e-mail, through Our website or otherwise. We collect several types of information from and about Users of our Website, including information:
- By which You may be personally identified, such as name, postal address, IP address, e-mail address, telephone number, geographical information, browser type and version, operating system, profile photo or any other identifier by which you may be contacted online or offline (“User Information“);
- That is about you but individually does not identify you; and/or
- About your internet connection, the equipment you use to access our Website and usage details.
We collect this information:
- Directly from You when You provide it to us.
- When You register online or place an order for our services.
- Automatically, as you navigate through the Website via Your browser’s cookies. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Information You Provide to Us
By using the Website, You agree that We maycollect, process, store and use data. The categories and types of Information we may collect, process, store and use include:
|Information that You provide by filling in forms on our Website or by voluntarily inputting such as through a Blog comment feature. This includes information provided at the time of registering to use the Website, subscribing to Our service, posting material, or requesting further services.||To provide You with more information on the Services Offered by the Company. To provide yourelevant opportunities from our Affiliate Companies.|
|Information You provide when You report a problem with our Website.||To assist in fixing issues and in evaluating how the website is working.|
|Records and copies of Your correspondence (including email addresses), if You contact us.||To assist Us in identifying You, contacting You, and keeping a record of Your interactions for the general knowledge of Us both.|
|Your responses to surveys that We might ask You to complete for research purposes.||For Company service improvement, client feedback, and market research purposes.|
|Your search queries on the Website.||If applicable, to track what Users are interested in and to improve Website functionality.|
|Your calendar dates.||If applicable, to assist Users and the Company to remember important dates.|
|Text message content.||To track User interaction with Company and facilitate User experience.|
|Your IP address and computer identifying information.||To track where User is interacting from for marketing purposes, safety, and quality control purposes.|
If You provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“), You agree that Your User Contributions are posted on and transmitted to others at Your own risk and You indemnify the Company from any and all damages incurred by it, whether through direct or third-party claims, and including all court costs, fees, and reasonable attorney’s fees incurred by the Company in relation thereto, including but not limited to all collections costs, court costs and reasonable attorney’s fees incurred in collections of any judgment there on.
If you are located in the U.S.,You agree that We may share or sell Your data with Companies at our discretion, so that they may offer You their products and services.
You shall have the right to request that We disclose to You the categories and specific pieces of Personal Information We have collected pertaining to You.We will only upon receipt of a verifiable consumer request.
You are above informed of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. We shall not collect additional categories of personal information or use personal information collected for additional purposes without providing You notice consistent with this section.
(d) A business that receives a verifiable consumer request from a consumer to access personal information shall promptly take steps to disclose and deliver, free of charge to the consumer, the personal information required by this section. The information may be delivered by mail or electronically, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, readily useable format that allows the consumer to transmit this information to another entity without hindrance. A business may provide personal information to a consumer at any time, but shall not be required to provide personal information to a consumer more than twice in a 12-month period.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical data and may include User Information or we may maintain it or associate it with User Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see How We Use and Disclose Your Information.
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Website.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Disclosure of Your Information
We follow HIPPA regulations concerning HIPPA protected private information.
We may disclose aggregated information about our users without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Donaldson Legal Counseling PLLC assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Donaldson Legal Counseling PLLC about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients. Also, where you have used our Website to procure the services of a practitioner, we may share your User Contributions with other Users who are seeking such services or practitioners.
- For any other purpose disclosed by us when you provide the information.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Our website and services are generally not intended for use by anyone under the age of 18, without the supervision of a parent or guardian, and we do not knowingly solicit information from or market to children under the age of 18.
In respect for the privacy of minors, the website does knowingly collect, maintain, or process personal information via out internet services by anyone under the age of 18. To the extent that the website collects personal information, the website will only do so with the required consent or as otherwise permitted under applicable laws.
Your California Privacy Rights
The California Consumer Privacy Act (CCPA) provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
California resident users have the right to request that Donaldson Legal Counseling PLLC., disclose certain information to you about our collection and use of your personal information over the past twelve months. Once the verifiable consumer request is received and confirmed, we will disclose:
- The categories of personal information collected about you
- The categories of sources for the personal information we collected about you
- Our business or commercial purpose for collecting or selling that personal information
- The specific pieces of personal information we collected about you (also known as the data portability request.)
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category or recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category or recipient obtained.
The Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods and services
- Charge you different rates for goods or services, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of goods and services
- Suggest that you may receive a different price or rate for goods and services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
To exercise the access, data portability, and deletion rights described above, submit a verifiable consumer request to us by either:
You, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a twelve-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
The Company cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do not consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org
We engage in certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, and direct marketing campaigns. We may share your personal information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
If a data breach occurs, we will promptly notify any User whose personal information was at risk, following the laws of the state of the User. If a mass breach occurs affecting multiple Users, we may post such information on our website among other methods of notification.
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;
- We may also send you additional information related to your product and/or service, if needed;
- Market to our mailing list after the original transaction has occurred.
Emails from Us will 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 in a timely manner.
If at any time you would like to unsubscribe from receiving future emails, you can email us at email@example.com and we will promptly remove you from all correspondence.
Up Spiral LLC
Tel: 929 444-2993