Last updated May 2020
Who we are
What personal data we collect and why we collect it
We may collect your personal data when you submit it to us (including though the Site and its Contact and Comments forms). Data that we may collect includes your:
- Email Address;
- Other data you provide in connection with any communications you may submit to us;
- Technical data, including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device identifiers, geolocation information, and other technology on the devices you use to access our Site; and
- Other sources, including via Google Analytics and social media.
Upon receiving your personal data, we may create a user profile linked to that personal data. If the same personal data is provided in connection with future activities associated with the Site, such actions will be added to that user profile. As described below, you may review and update such information at any time.
When visitors leave messages on the Site, we may collect the data shown in the Comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
When you visit any website (including our Site), it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the Site work as you expect them to. The information does not usually directly identify you, but it can give you a more personalized web experience.
Using the settings of your Internet or mobile browser, you can choose to have your computer warn you each time a cookie is being sent. Because we respect your right to privacy, you can choose not to allow some types of cookies. However, if you choose to disable any cookies, some features of the Site may become disabled, and some aspects of the Site may not function properly.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
Sharing of your personal data
We do not disclose your personal data to any third parties, except (i) to manage the Site with the help of service providers (who are obligated to maintain its confidentiality), (ii) to send you communications in response to your interactions with us or about features of the Site, including any future changes to this Policy, or (iii) as required by law or requested by governmental or law enforcement authorities, subpoena, court order or discovery request, or when we otherwise believe in good faith that such disclosure is appropriate to enforce our Terms of Service or in connection with any activity that may violate the law or the rights of others, threaten the safety or security of any person or property (including the Site) or expose us to liability.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can fulfill the purposes for which we have collected it, such as to recognize and approve any follow-up comments automatically instead of holding them in a moderation queue, and also as necessary to satisfy any legal, regulatory, accounting, reporting, insurance, professional indemnity, internal policy or other requirements. Website administrators can also see and edit this information, and are obligated to maintain its confidentiality.
We may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. In such cases, we may use this information indefinitely without further notice to you.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
The Site is not targeted toward, and we do not seek or desire to collect information from, children under the age of 13 in the United States (or age 16 outside the United States). Therefore, we will not knowingly request information from persons under such ages. Please do not provide any personal data to us for any reason unless you are at least the age of 13 in the United States (or age 16 outside the United States), and please caution your children not to do so.
If a child under the age of 13 in the United States (or age 16 outside the United States) has provided personal data to us through the Site without verifiable parental consent, a parent or guardian may inform us through the Contacts form, and we will use commercially reasonable efforts to delete such information within a reasonable period of time, subject to applicable law and this Policy.
California privacy rights / “Do Not Track” signals
We do not track its users over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain web browsers allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know that you do not want to be tracked. You should consult your web browser’s “help” feature for instructions on how to set the DNT signal.
We have implemented appropriate technical and organizational measures to ensure a level of security of personal data appropriate to the risk.
This Policy applies only to the Site. If you visit any unaffiliated website linked to the Site (for example, social media sites), you are subject to that entity’s own privacy policies, which we do not control or monitor. You should review the privacy policies of all third-party websites before you visit them. We have not reviewed all of the sites linked to the Site and makes no representations or warranties as to the privacy practices, functioning or content of any sites linked to the Site.
How you can access and manage your information
You can review and update certain of your personal data, and can also opt out of any type of communication from us, at any time, by contacting us with this request through the Contacts form.
We are based in the United States, and our computer servers are located in the United States. Accordingly, all personal data in our possession and control is collected and processed by us in the United States. Any party that provides personal data to us is thereby transferring such data to the United States.
Access to the Site from countries or territories where such access is illegal or contrary to applicable rules or regulations is prohibited. Those who access the Site from outside the United States do so on their own initiative and are responsible for compliance with local laws, rules and regulations.
Rights of individuals in the European Union
This section applies only to individuals in the European Union (the “EU”).
With respect to the personal data we collect directly from you, we are the “data controller,” as defined in the European Union’s General Data Protection Regulation (the “GDPR”).
We will only use your personal data when we have a lawful basis to do so under the GDPR. Usually, we will use your personal data in the following circumstances:
- when it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests;
- when we need to comply with a legal or regulatory obligation; or
- when we have obtained your consent.
Under the GDPR, individuals in the European Union (“EU Individuals”) have certain rights in relation to their personal data, which are summarized below. These rights are subject to your exercising them in good faith and are subject to our legitimate interests or other valid basis to continue processing your personal data, in accordance with our policies and applicable law.
If asked by an EU Individual and if we are obligated to do so under applicable law, we will inform that individual about whether we are processing his/her personal data. If we are processing such EU Individual’s personal data, we will provide access to the personal data that we have about that individual. If you request additional copies of your personal data, we may charge you a reasonable fee.
Rectification (i.e., Correction)
If the personal data we hold about an EU Individual is inaccurate or incomplete, that individual may ask us to have it corrected.
EU Individuals may request that we erase (i.e., delete or remove) their personal data in certain circumstances. If you are legally entitled to erasure, and if we have shared such personal data with third parties, we will take reasonable steps (taking into account available technology and the cost of implementation) to inform such third parties of your request, to the extent we are required to do so by applicable law.
Restriction of Processing
EU Individuals have the right to restrict the processing of their personal data in certain circumstances, such as if they contest the accuracy of that personal data, if the processing of the personal data is unlawful, or if we no longer need the personal data for our business purposes. If you are legally entitled to restriction, and if we have shared your personal data with others, we will use reasonable efforts to inform such third parties of your request, if we are required to do so.
EU Individuals may ask to receive their personal data from us, where the legal basis of our processing is their consent, and where we carry out the processing of their personal data by automated means. If EU Individuals so request, we may transmit their personal information directly to another organization if it would be technically feasible to do so.
Objection to Processing
EU Individuals may object to the processing of their personal data where we are relying on a legitimate interest (or those of a third party). As noted above, you also have the right to object (i.e., opt out of) our processing of your personal data for direct marketing purposes.
Automated Decision-Making and Profiling
EU Individuals have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us. We do not engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning an individual or similarly significantly affects an individual.
Processing of Special Categories of Personal Data
There are certain types of personal data that require a higher level of protection, known as “special categories” of personal data under the GDPR. We do not process special categories of personal data unless (a) we have obtained such individuals’ explicit consent or (b) we are otherwise legally permitted to do so.
In certain circumstances, EU Individuals have the right to withdraw their consent to our processing of their personal data. However, withdrawal of consent will not affect the lawfulness of any processing that had been carried out before consent is withdrawn. Moreover, if we rely on another legal basis (e.g., legitimate interest) to process your personal data, we may continue to process your personal data in accordance with such other legal basis even after you withdraw your consent. If you decide to withdraw your consent, we may not be able to provide certain services to you.
Please note that where we rely on consent to use your personal data, all users worldwide have the right to withdraw that consent at any time. This includes the option to unsubscribe from our email list at any time or to contact us to request to be excluded from our online campaign promotion lists or text messaging.
EU Individuals who wish to exercise any of the rights they have under the GDPR should contact us through the Contacts form. We may need to request specific information to help us confirm your identity, so that your 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.
Generally, EU Individuals will not have to pay a fee to exercise the rights described above. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
EU Individuals may lodge a complaint with the appropriate regulatory body or supervisory authority in the country where they reside, where they work, or in the place of the alleged infringement of the law.