Effective date: May 22, 2018
The purpose of this policy is to explain to you how we control, process, handle and protect your personal information while browsing or using this website, including your rights under current laws and regulations. If you do not agree to the following policy you may wish to cease viewing / using this website.
Policy key definitions:
- "I", "our", "us", "we", or "Owner" refer to the individual, Renée M. LaTulippe and The Lyrical Language Lab.
- "you", "the user" refer to the person(s) using this website.
- "website" refers to this website, www.reneelatulippe.com.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner's Office.
- Cookies mean small files stored on a user's computer or device.
Personal Data Collected
We collect information from you when you subscribe to a newsletter or enter information on our website. Our opt-in subscription forms collect personally identifiable information that includes, but is not limited to:
- Email address
- First name
Your Personal Data is used to contact you with newsletters and marketing materials pertaining to The Lyrical Language Lab and other writing services, including class session sign-up announcements, changes to services, free writing webinars/articles/tips, and other information that may be of interest to you. You may unsubscribe from these communications by following the unsubscribe link provided in every email or by contacting us at email@example.com.
Lawful Bases for Personal Data Processing
Under the GDPR (General Data Protection Regulation) we control and/or process any personal information about you electronically using the following lawful bases.
- Consent: You have given us permission to do so.
- Contract: We may need to enter into a contract with you for services.
- Legitimate interests: Processing may be necessary to provide services or process payments.
Data retention period: We will continue to process your information under these bases until you withdraw consent or it is determined your consent no longer exists.
If, as determined by us, the lawful bases upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Sharing Your Information
We do not sell, trade, or otherwise transfer your personal information with third parties not affiliated with Renée M. LaTulippe or The Lyrical Language Lab. 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.
Your Individual Rights
Under the GDPR your rights are as follows. You can read more about your rights in details here.
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Some cookies are required to enjoy and use the full functionality of this website.
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. You can enable or disable the DNT feature in your browser's settings.
Data Security and Protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Email Marketing Messages & Subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Personal Data Collected" above. Any email marketing messages we send are done so through an EMS (email marketing service provider). An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons and/or tracked clickable links and/or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as times, dates, IP addresses, opens, clicks, forwards, and geographic and demographic data. Such data, within its limitations, will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences and/or the information we hold about you at any time. See any of our marketing messages for instructions on how to unsubscribe or manage your preferences.
Our EMS provider is MailChimp.com. We hold the following information about you within our EMS system:
- Email address
- First name
- Subscription time & date
This website uses the third-party analytics service Google Analytics to track and report activity. Google Analytics is a piece of software that captures various data about our website users, including but not limited to:
- What website users originate from
- How long users stay on this website
- What kind of computer the user is using
This tracking information allows us to better understand who uses this website and which content they are accessing, which in turns helps us improve and modify our content. This data is also shared with other Google services, which may use the collected data to contextualize and personalize the ads of its own advertising network.
To opt out of tracking...
Occasionally, at our discretion, we may include or offer third-party products or services on our website, or post links to other sites in the form of text links and embedded videos. These third-party sites and links 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.
California Online Privacy Protection Act (CalOPPA)
In Accordance with CalOPPA, we agree to the following:
Users can visit our site anonymously.
Users can change their personal information by emailing us at firstname.lastname@example.org.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 18 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 18 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.
To be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify users via email within 1 business day.
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.
Resources & Further Information
- Overview of the GDPR - General Data Protection Regulation
- Data Protection Act 1998
- Privacy and Electronic Communications Regulations 2003
- The Guide to the PECR 2003
- Small business GDPR policy template