UPDATED May 16, 2018

  1. INTRODUCTION

Jenna Barwin is committed to protecting your privacy. We also promise not to spam you. No one wants a ton of email clogging up their inbox. We understand the trust you place in us when you provide us with your name, email address and any other personally identifiable information. We won’t abuse that trust.

This privacy notice provides you with details of how we collect and process your personal data through your use of our site, JennaBarwin.com, as well as any personal data we collect offline. Any personally identifiable information collected is used and disclosed as described in this Privacy Policy. By using this website, you are accepting and consenting to the practices described in this Privacy Policy.

If you do not agree to the terms of this Privacy Policy, please do not use this website.

  1. YOU MUST BE AT LEAST 18 YEARS OLD TO USE THIS WEBSITE

By providing us with your data, you warrant to us that you are over 18 years of age. JennaBarwin.com is directed to adults 18 years and older. You must be at least 18 years old to use this website. Additionally, you must be at least 18 years of age to subscribe to our newsletter or become an Early Reviewer.

  1. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify or amend the terms of our Privacy Policy from time to time without advance notice. If we make a material change in the way we use your personally identifiable information, we will provide prominent notice of the change on this Privacy Policy page and update the policy date at the bottom of this page. Your continued use of the website or continued receipt of our newsletter or other email communications following the posting of changes to these terms will mean you accept those changes, unless we are legally required to obtain your affirmative consent.

Some of you (in particular, European users) have certain legal rights. We will use reasonable efforts to identify European users covered and obtain any required consent when we change or materially modify our Privacy Policy.

  1. DATA WE COLLECT ABOUT YOU AND ITS PURPOSE

Personally identifiable data means any information capable of identifying an individual. It does not include anonymized data.

a. Examples of personally identifiable data processed (see 4.b. for a full description):

We collect personally identifiable information from you when you become a VIP Reader (i.e., subscribe to Jenna Barwin’s Newsletter), become an Early Reviewer (i.e., sign up to receive advance review copies of Jenna Barwin’s books), respond to a survey, enter a giveaway, fill out a form or enter information on our site, browse our website, or as described more fully below.

When you sign up as a VIP Reader, we use the information you provide to send you our newsletter by email with the latest news, updates, articles, offers and promotions from author Jenna Barwin.

When you sign up as an Early Reviewer, we use the information you provide to determine your eligibility to become an Early Reviewer and communicate with you about the Early Reviewer process and to distribute advance review copies to you.

Jenna Barwin’s Newsletter and communications with Early Reviewers types of marketing communications, which are more fully described below.

When you respond to a survey, enter a giveaway, or respond to a promotion, we use the information you provide to administer and analyze the survey, giveaway, or promotion, and may use the information collected to guide our marketing efforts and to communicate with you.

When you communicate with us by using the site’s contact form, by emailing us, or by using any other means of communication, we collect the names and email addresses of those who communicate with us, and any other information provided in those communications. In part, we use the information you provide to respond to a communication you initiate.

You may visit our site anonymously. However, your IP address is logged by our web hosting service for systems administration and troubleshooting purposes whenever you visit the site and we use cookies, as discussed below. We also use page hits in the aggregate to track the popularity of pages that people visit in order to improve the quality of the site.

b. We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business.

Technical Data that includes data about your use of our website and online services such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws, free giveaways and price reductions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.

Contractor Data that includes data provided by the contractors we retain to perform services for us, such as tax ID numbers and other information that by law we must collect and process. We process this data to ensure compliance with contractual and legal requirements.

We may use Communication Data, User Data, Technical Data and Marketing Data to send marketing communications to you, including without limitation Jenna Barwin’s Newsletter and Early Reviewer communications.

c. Sensitive Data

We do not collect any Sensitive Data about website users. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

d. Personal Data Collected by Law or Where Required by Law

Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you, or make payment to you). If you don’t provide us with the requested data, we may have to cancel a product or service ordered but if we do, we will notify you at the time.

e. Reasonably Compatible Purposes

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@jennabarwin.com.

f. No automated decision-making or profiling

We do not carry out automated decision making or any type of automated profiling.

  1. HOW WE COLLECT YOUR PERSONALLY IDENTIFIABLE DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails), or by you providing data to a third party and consenting to the transfer of the data to us (e.g., a multi-author giveaway). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy below for more details.

Our service providers may automatically collect certain data from you when you open a newsletter or other email communication, such as the date and time you opened an email from us and whether you clicked any links or downloaded a file, and this information is shared with us. The date you are added to a service provider system (such as our email automation system), and the date you change any information recorded in that system is usually logged by our service provider. Our service provider may also make a reasonable approximation of your location based on your IP address.

If you are in the European Union, please see 16 below for more detail.

  1. CORRECTING OR AMENDING YOUR PERSONALLY IDENTIFIABLE DATA

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@jennabarwin.com or use the contact form here: https://jennabarwin.com/contact/

For California residents or any user where their local law requires the same, we will provide you with reasonable access to your personal information upon written request made via email or regular mail (see “Contact Information” below), and we will respond within forty-five days unless applicable law requires a sooner response time.

If you are in the European Union, please see 16 regarding your additional rights.

  1. NO THIRD PARTY COMMERCIAL OR MARKETING COMMUNICATIONS

We do not sell, trade, or otherwise transfer to outside third parties your personally identifiable information unless we provide users with advance notice. We do not share your personal data with any third party for their commercial or marketing purposes. Before we share your personal data with any third party for their own commercial or marketing purposes we will get your express consent.

This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, serving our users, managing our email list, distributing our newsletter, or are our successors or assigns, so long as those parties agree to keep this information confidential. See section 9 below for additional details.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

  1. OUR PROMISE NOT TO SPAM YOU; HOW TO OPT-OUT/UNSUBSCRIBE

We agree to the following for any commercial or marketing messages we send:

  • Not to use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way unless the recipient has affirmatively consented to receiving messages from us.
  • Include the physical postal address for our business.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

You can ask us to stop sending you commercial or marketing messages at any time by following the unsubscribe links on any commercial or marketing email sent to you or by emailing us with your request at info@jennabarwin.com at any time.

If you unsubscribe and opt out of receiving commercial or marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, giveaways, etc.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services, including website hosting and programming.
  • Professional advisers including lawyers, bankers, auditors and insurers.
  • Government bodies that require us to report processing activities.
  • Service providers who manage the distribution of advance review copies or through whom we distribute giveaway prizes.
  • Service providers who manage our email list, including distribution of our newsletter.
  • Service providers who manage giveaways.
  • Service providers who provide cloud storage or cloud software.
  • Service providers who provide survey services.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to keep this information confidential. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

However, we may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.

  1. GOVERNING LAW

This website is published in the United States. We attempt to protect the personally identifiable information of all users of the site and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to our site, but this site is located and targeted to United States citizens and our policies are directed at compliance with those laws. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your personally identifiable information to us.

a. California Online Privacy Protection Act (CalOPPA)

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act.

b. Children Online Privacy Protection Act (COPPA)

We care about the safety and privacy of children online, and we comply with the federal Children’s Online Privacy Protection Act of 1998. We do not knowingly contact or collect personally identifiable information from children under the age of 13 on this website. Our site is not intended to solicit information of any kind from children under the age of 13. Our website, products and services are all directed to people who are at least 13 years old or older.

If we discover we have received any information from a child under 13 in violation of this policy, we will delete that information immediately. If you believe our site has any information from or about anyone under the age of 13, please contact us.

  1. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees, contractors, or service providers who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to. Unless applicable laws require an earlier notice, in the event of a data breach we will notify you via email within 7 business days and we will also provide notification of such on our site within 7 business days.

  1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our contractors (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being contractors. In some cases where the transfer of rights is involved, the retention may be permanent.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. THIRD-PARTY LINKS INCLUDING SOCIAL MEDIA BUTTONS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

a. What’s a cookie?

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

b. Your choice regarding cookies

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies. If you turn cookies off to block all cookies (including essential cookies), some features will be disabled and may not function properly.

c. How do we use cookies?

We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.

Cookies are either:

  • Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
  • Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We do not currently use Google Analytics, but reserve the right to add it in the future. Google Analytics is a web analytics tool used to help understand how visitors engage with this website. It reports website trends using cookies and web beacons without identifying individual visitors. Google Analytics uses persistent cookies. You can read more about it by searching for the Google Analytics Privacy Overview.

Cookies can also be categorized as follows:

  • Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
  • Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.
  1. HOW WE RESPOND TO DO NOT TRACK SIGNALS

At this time, we do not honor Do Not Track signals.

  1. COMPLIANCE WITH EUROPEAN DATA PROTECTION LAWS

We are located in the United States and process data in the United States. Some of our service providers may process data in locations other than the United States.

If you are a user in the European Union (EU), this Section 16 applies to you. It also applies to you if, after the United Kingdom (UK) separates from the EU, you are in the UK and the UK maintains a law substantially similar to the EU data protection laws.

a. The categories of data we collect are described above. The following are the grounds on which we process the data we collect:

Communication Data: Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

User Data: Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business.

Technical Data: Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data: Our lawful ground for this processing is our legitimate interests, which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

Contractor Data: Our lawful ground for this processing is it is necessary for the performance of a contract, to fulfill a legal obligation, and our legitimate interests, which in this case are to enable us to properly administer our business.

Commercial or Marketing Communications: Our lawful ground of processing your personal data to send you commercial or marketing communications is either your consent or our legitimate interests (namely to grow our business).

Reasonably Compatible Purposes: In case we need to use your personal data for an unrelated new purpose we will let you know and explain the legal grounds for processing.

Personal Data Collected by Law or Where Required by Law: We may process your personal data without your knowledge or consent where this is required or permitted by law.

b. Additional data sources

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

c. European Users Legal Rights

Under European data protection laws, if you are in the EU (or UK after separation) you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://www.dataprotection.ie/docs/A-guide-to-your-rights-Plain-English-Version/r/858.htm

If you wish to exercise any of the rights set out above, please email us at info@jennabarwin.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that 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 to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, we would be grateful if you would contact us at info@jennabarwin.com first if you do have a complaint so that we can try to resolve it for you. If you are in the EU, you also have the right to complain to the Data Protection Commissioner, the Ireland supervisory authority for data protection issues (https://www.dataprotection.ie/).

d. International Transfers

Countries outside of the European Economic Area (EEA) (or outside the UK after UK separation from the EU) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

We are located in the United States. Most of our third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
  • Where we use certain service providers who are established outside the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

For VIP Readers and Early Reviewers, we have requested your explicit consent to certain transfers, which are detailed under “Data Transfer Risk Disclosure—Notice to Non-US Users” (below).

  1. DATA TRANSFER RISK DISCLOSURE—NOTICE TO NON-US USERS:

If you are located outside the United States of America, you should be aware that your personally identifiable information will be transferred to the United States of America or possibly other locations used by our service providers, the laws of which may be deemed by your country to have inadequate data protection. If you are located in a country outside the United States of America and voluntarily submit personally identifiable information to us on this website or via electronic communications, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States of America or other locations.

For Non-US users, we have requested your specific consent to the following transfers:

The service provider we use to distribute free books is based in the United States and as of this writing, is not part of EU-US Privacy Shield. That service provider is currently trying to decide whether they will become EU-US Privacy Shield certified, or if they will enter into data processing agreements to give personal data the same protection it has in Europe. We provide that service provider with your name and email address when we distribute free books through them, such as to Early Reviewers or giveaway winners. In addition to the information we provide, they track whether and when you download a book through their service. They have a privacy policy in place, and we will provide the link upon request if you email us at info@jennabarwin.com.

The service provider we use to host our website and email is based in the United States, Europe, and Asia, and as of this writing, is not part of EU-US Privacy Shield, although they report they are working on qualifying. They process Communication Data, User Data, Technical Data and Marketing Data for us.

The possible risk of such transfers to service providers outside your country (or for European users, outside the EEA) is that your personally identifiable information may not be handled as proscribed by laws governing your data and could increase the risk of release of your personally identifiable information to unintended persons.

  1. CONTROLLERS OF PERSONALLY IDENTIFIABLE INFORMATION

Jenna Barwin is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

  1. CONTACT INFORMATION

Our full contact details are:

Jenna Barwin, 32565-B Golden Lantern Street #129, Dana Point, California 92629.

info@jennabarwin.com

  1. ENFORCEMENT OF THIS PRIVACY POLICY

Jenna Barwin welcomes your comments regarding this Privacy Policy. If you believe that we have not adhered to this Policy or if you have questions regarding this privacy policy, contact Jenna Barwin via email at info@jennabarwin.com or by mail to Jenna Barwin, 32565-B Golden Lantern Street #129, Dana Point, California 92629.

Effective date 2018-05-16

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