Our
Privacy Policy
This
version was posted
on 18 October, 2010
and remains in
effect until
supplanted.
I. Overview: I/we recognize
that privacy is
important. This
Privacy Policy
applies to all of
the products,
services and
websites owned or
operated by Rich Van
Winkle. I/we attempt
to adhere to the US
Safe Harbor Privacy
Principles of
Notice, Choice,
Onward Transfer,
Security, Data
Integrity, Access
and Enforcement. If
you have any
questions about this
Privacy Policy,
please feel free to
contact me through
any of my websites
or write to me at:
Rich Van Winkle,
P.O. Box 5413,
Bellingham, WA
98227.
We (Rich and associates)
offer a number of
services that do not
require you to
register for an
account or provide
any personal
information. In
order to provide
services, we may
collect the
following types of
information:
II. Information You
Provide: When you
use any of our
websites and request
contact or a service
that requires
information, we may
ask you for personal
information (such as
your name, email
address and an
account password)
that we deem
necessary to provide
the requested
service or offer the
requested contact.
For certain
services, such as a
store purchase, we
request credit card
or other payment
account information
which is maintained
in encrypted form in
secure systems. We
may combine the
information you
submit under your
account with
information from
other services or
third parties in
order to provide you
with a better
experience and to
improve the quality
of service.
III. Cookies and Server
Logs: When you visit
any of our websites,
we may send one or
more cookies – a
small file
containing a string
of characters – to
your computer or
other device that
uniquely identifies
you, your browser,
or other web traffic
information. Cookies
improve the quality
of our service by
storing user
preferences,
improving search
results and tracking
user trends. We may
keep a record of
what portions of our
websites you’ve
accessed and for how
long. Whatever
information we
gather from our
cookies and our
served logs remains
our property and we
will not make that
information
available to you or
anyone else. Most
browsers are
initially set up to
accept cookies, but
you can reset your
browser to refuse
all cookies or to
indicate when a
cookie is being
sent. However, some
features and
services may not
function properly if
your cookies are
disabled and we
reserve the right to
deny service because
cookies are disabled
(or for any other
reason we deem fair
and legal).
IV. User Communication:
When you send email
or other
communications to
us, we may retain
such communications
in order to process
your inquiries,
respond to your
requests and improve
our services.
V. Links: We may present
links in a format
that enables us to
keep track of
whether these links
have been followed.
We use this
information to
improve the quality
of our services and
determine user
preferences. This
Privacy Policy
applies to our
services on our
websites only. We do
not exercise control
over the sites
displayed as search
results, sites that
we link to, or links
from within our
related services.
These other sites
may place their own
cookies or other
files on your
computer, collect
data or solicit
personal information
from you.
VI. Affiliated Services On
Other Sites: We
offer some of our
services on or
through other web
sites. Personal
information that you
provide to those
sites may be sent to
us in order to
deliver the service.
We process such
information under
this Privacy Policy.
The affiliated sites
through which our
services are offered
may have different
privacy practices
and we encourage you
to read their
privacy policies.
We only processes personal
information for the
purposes described
in this Privacy
Policy and the
following:
·
Providing our services,
including the
display of
customized content
and advertising;
·
Auditing, research and
analysis in order to
maintain, protect
and improve our
services;
·
Ensuring the technical
functioning of our
network;
·
Protecting our rights or
property and that of
our other users; and
·
Developing new services.
We
processes
personal information
on hosted servers in
the United States of
America. In some
cases, our hosts may
process personal
information on
servers outside of
your own country. We
may process personal
information to
provide our own
services. In some
cases, we may
process personal
information on
behalf of and
according to the
instructions of a
third party, such as
our advertising
partners.
VII. Choices for personal
information: When
you sign up for a
particular service
that requires
registration or
input of personal
information, we may
use this information
in a manner
different than the
purpose for which it
was collected. At
our discretion, we
may ask for your
consent prior to
such use. If we
intend to use
personal information
for any purposes
other than those
described in this
Privacy Policy
and/or in the
specific service
privacy notices, we
will either notify
you of such, offer
you an effective way
to opt out of the
use of personal
information for
those other
purposes, or both.
We will not collect
or use sensitive or
financial
information for
purposes other than
those described in
this Privacy Policy
and/or in the
supplementary
service privacy
notices, unless we
have obtained your
prior consent.
VIII. Information sharing:
We only share
personal information
with other companies
or individuals in
the following
limited
circumstances:
1.
If we have your
consent. We require
opt-in consent for
the sharing of any
sensitive personal
information.
2.
If we provide such
information to our
subsidiaries,
affiliated companies
or other trusted
businesses or
persons for the
purpose of
processing personal
information on our
behalf, we require
that those parties
agree to process
such information
based on our
instructions and in
compliance with this
Privacy Policy and
any other
appropriate
confidentiality and
security measures.
3.
If we have a good
faith belief that
access, use,
preservation or
disclosure of such
information is
reasonably necessary
to (a) satisfy any
applicable law,
regulation, legal
process or
enforceable
governmental
request, (b) enforce
applicable Terms of
Service, including
investigation of
potential violations
thereof, (c) detect,
prevent, or
otherwise address
fraud, security or
technical issues, or
(d) protect against
harm to the rights,
property or safety
of ourselves, our
company, our users
or the public as
required or
permitted by law.
4.
If we become
involved in a
merger, acquisition,
or any form of sale
of some or all of
its assets, we will
ensure the
confidentiality of
any personal
information involved
in such transactions
and provide notice
before personal
information is
transferred and
becomes subject to a
different privacy
policy.
5.
If we share with
third parties
certain pieces of
aggregated,
non-personal
information, such as
the number of users
who searched for a
particular term or
how many users
clicked on a
particular
advertisement, such
information will not
identify you
individually.
IX. Information Security
and Integrity: We
process personal
information only for
the purposes for
which it was
collected and in
accordance with this
Privacy Policy or
any applicable
service-specific
privacy notice. We
review our data
collection, storage
and processing
practices to ensure
that we only
collect, store and
process the personal
information needed
to provide or
improve our services
or as otherwise
permitted under this
Policy. We take
reasonable steps to
ensure that the
personal information
we process is
accurate, complete,
and current, but we
depend on our users
to update or correct
their personal
information whenever
necessary.
We take appropriate
security measures to
protect against
unauthorized access
to or unauthorized
alteration,
disclosure or
destruction of data.
These include
internal reviews of
our data collection,
storage and
processing practices
and security
measures, as well as
physical security
measures to guard
against unauthorized
access to systems
where we store
personal data.
We restrict access to
personal
information. Our
employees,
contractors,
associates
and agents
who need to know
that information in
order to operate,
develop, or improve
our services are
required to know and
accept this Privacy
Policy (in writing).
Where that
information includes
personally
identifying data,
the individuals with
access are bound by
confidentiality
obligations and may
be subject to
discipline,
including
termination and
criminal
prosecution, if they
fail to meet these
obligations.
X. Accessing and Updating
Personal
Information: When
you use our
services, we make
good faith efforts
to provide you with
access to your
personal information
and either to
correct this data if
it is inaccurate or
to delete such data
at your request if
it is not otherwise
required to be
retained by law or
for legitimate
business purposes.
We ask individual
users to identify
themselves and the
information
requested to be
accessed, corrected
or removed before
processing such
requests, and we may
decline to process
requests that are
unreasonably
repetitive or
systematic, require
disproportionate
technical effort,
jeopardize the
privacy of others,
or would be
extremely
impractical (for
instance, requests
concerning
information residing
on backup tapes), or
for which access is
not otherwise
required. In any
case where we
provide information
access and
correction, we
perform this service
free of charge,
except if doing so
would require a
disproportionate
effort. Some of our
services have
different procedures
to access, correct
or delete users’
personal
information.
XI. Changes and Challenges
to This Privacy
Policy: Please note
that this Privacy
Policy may change
from time to time.
We will not reduce
your rights under
this Privacy Policy
without providing
reasonable notice
and we expect most
such changes will be
minor. Regardless,
we will post any
Privacy Policy
changes on this page
and, if the changes
are significant, we
will provide a more
prominent notice
(including, for
certain services,
email notification
of Privacy Policy
changes). Each
version of this
Privacy Policy will
be identified at the
top of the page by
its effective date,
and we will also
keep prior versions
of this Privacy
Policy in an
archive.
When we receive formal
written complaints
regarding privacy
matters or personal
information, it is
our policy to
directly contact the
complaining user
regarding those
concerns. We will
cooperate with the
appropriate
regulatory
authorities,
including local data
protection
authorities, to
resolve any
complaints regarding
the transfer of
personal data that
cannot be otherwise
resolved.
COPPA
Compliance: We (this and all other
associated websites)
do not knowingly
collect or store any
personal
information, even in
aggregate, about
children under the
age of 13.
Technology on the Internet
is developing at a
rapid pace, and we
need to maintain our
flexibility in the
online arena. If we
need to change our
policy in the
future, we will post
these changes as
soon as they go into
effect.
If you have any additional
questions or
concerns about this
Privacy Policy,
please feel free to
contact us any time
through this web
site or the other
listed contact
options (as above).
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