Privacy

Lawyer Notes Re: Updated Privacy Policy Further to your request, I have attached a draft privacy policy for the TimeSlips website. We structured this privacy policy based on your responses to the questionnaire (attached). Please keep in mind that the most important aspect of any privacy policy is that it accurately, completely, and understandably describes the company's privacy practices – information collection, use, sharing etc. Thus, it is important that all applicable personnel review the policy to confirm it is accurate and complete. If you find that any of the information provided is inaccurate or changes, please let us know so we can make appropriate revisions to the policy. A quick note about the format compared to your older privacy policy. The format layout text in the bubble preceding in each section is designed to provide a layered privacy policy. While recommended, they are still optional. If you choose to use them, they may be implemented any way you wish. Some example implementations include having them always present with the text below them, requiring a user to click on them to see the text below, or moving them to the top of your privacy webpage and having the user click on each section to jump to the text below. TimeSlips Creative Storytelling, Inc. Privacy Policy Last modified: March 19, 2019 Introduction TimeSlips Creative Storytelling, Inc. (“TimeSlips” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website http://www.timeslips.org (our “Website”) and our practices for collecting, using, protecting, and disclosing that information. This policy applies to information we collect: on our Website; in person at a training event or over the phone; and in email, text, and other electronic messages between you and our Website. It does not apply to information collected by: use offline or through any other means, including on any other website operated by TimeSlips or any third party; or any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. Children Under the Age of 13 Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use, provide information on our Website through any of its features or create an account. Do not 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 on our Website. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@timeslips.org. Information We Collect About You and How We Collect It Generally We collect several types of information from and about users of our Website, specifically information (“Personal Data”): by which you may be personally identified, such as your name, pictures, videos, postal address, email address, telephone number, home address, work address, billing address or any other identifier by which you may be contacted online or offline; that is about you but individually does not identify you, such as traffic data, location data, date and time of your visit to our Website, referring/exit pages, age range, occupation, pronoun, education, other communication data and the resources that you access and use on the Website; about your internet connection, the equipment you use to access our Website and usage details; and other personal data you may include in the stories that you upload or when you make a donation or purchase a product. We collect this information: directly from you when you provide it to us (such as in your profile and through the stories you upload); and automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies. Information You Provide to Us The information we collect on or through our Website is: information that you provide by filling in forms and interacting with our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, purchasing products or services, giving donations or requesting further services. We may also ask you for information when you report a problem with our Websites; records and copies of your correspondence (including email addresses), if you contact us; your responses to surveys that we might ask you to complete for research purposes; and your search queries on the Website. If you refuse to provide such Personal Data or opt-out to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it. You also may 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”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom your User Contributions are shared with. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. 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, specifically: details of your visits to our Website such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and information about your computer and internet connection such as your IP address, operating system, and browser type. The information we collect automatically is statistical data and does not include Personal Data, but we may maintain it or associate it with Personal Data 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 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; and recognize you when you return to our Website. How We Use Your Information We use information that we collect about you or that you provide to us, including any Personal Data: 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/certification, including expiration and renewal notices; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us; 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; to track you as you complete different stages of training; to track you when you post User Contributions; to maintain and update a list of Certified Facilitators; and in any other way we may describe when you provide the information. We may use your information to contact you about our goods and services that may be of interest to you. If you no longer wish for us to use your email address to contact you, please click on the “unsubscribe” link in our emails, or contact us at info@timeslips.org. For more information, see Choices About How We Use and Disclose Your Information. Disclosure of Your Information We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Data that we collect or you provide as described in this privacy policy: to contractors, service providers, and other third parties we use to support our business. For example, our donation services and fundraising services are provided by third parties so your information may be transmitted to different websites; 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 TimeSlips’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by TimeSlips about our Website’s users, Certified Facilitators are among the assets transferred; to third parties who manage facilities in which training programs are held if you decide to participate in these training programs; to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide the information; and with your consent. We may also disclose your Personal Data: to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce or apply our Terms of Service and other agreements; and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TimeSlips, our users, Certified Facilitators, or others. Choices About How We Use and Disclose Your Information We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information in strict confidentiality. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes. In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data: Tracking Technologies. Unless you have adjusted your browser setting so that it will refuse cookies, our system or third parties will issue cookies when you direct your browser to our Website. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. Promotional Communications from TimeSlips. We will use your email address and postal address to send you newsletters, pricing information, surveys, and other communications if you check the relevant boxes located on the form on which we collect your Personal Data. You can request to stop receiving communications by contacting us via email at info@timeslips.org or if we have sent you a promotional email, you can click on the “unsubscribe link” in the email. This opt out does not apply to information provided to TimeSlips as a result of a product purchase, or other transactions. Third Party Cookies. Some content or applications on our Website is served by third parties. These third parties may use cookies to collect information about you when you access our Website. The information they collect may be associated with your Personal Data or they may collect information including Personal Data, your online activities over time and across different websites and other online services. We do not control these third parties’ tracking technologies or how they may be used. Analytics Cookies and Similar Technologies. Analytics cookies and other similar technologies used by us collect information about your use of the Website and enable us to improve the way it works and operates. Analytics cookies provide us with information regarding what the most frequently visited pages on the Website are, the time spent on each page, how the User arrived at the page, and User IT information. These analytics cookies do not allow us to see the usage of a single user, but does allow us to see overall patterns of usage on the Website. We do not examine this information for individually identifying information, but we do use this information to understand the traffic on our Website. Your Rights Regarding Your Information and Accessing and Correcting Your Information Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data. Access and Update. You can review and change your Personal Data by logging into the Website and clicking on “Settings” and then “Edit User”. You may also notify us through the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect. Deleting your Account. You can close your online account by emailing us at info@timeslips.org. If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information for archival purposes, and to avoid identity theft or fraud. Your California Privacy Rights California law permits minors under the age of 18 to request the removal of your User Contributions, subject to certain exceptions. If you are under the age of 18 in California, you may contact us using the contact information below (if you contact us via email, please use the subject “California Eraser Law Request”). We may not remove your User Contributions that we are required to retain under any federal or state law, or that have been provided to a third party. While we will do our best to remove a minor’s information upon a valid request, we cannot ensure the complete or comprehensive removal of your User Contributions from our Website or any information that has been republished, copied, downloaded, or reposted by any third party, and we cannot guarantee that any such information may not be accessible to users of the Internet in the future. We do not advertise or market any of the products or services identified in California Business and Professionals Code Section 22580(i) to users who we have actual knowledge are under 18 years of age. Do Not Track Signals We may use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received. Data Security We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. 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 story 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 Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. Changes to Our Privacy Policy We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Websites’ home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account or through a notice on the Website’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes. Contact Information If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Website. To Contact TimeSlips TimeSlips Creative Storytelling Inc. 4461 N. Lake Dr. Milwaukee, WI 53211 United States of America info@timeslips.org