UPDATED May 16, 2018
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.
- 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.
- 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.
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 email@example.com.
f. No automated decision-making or profiling
We do not carry out automated decision making or any type of automated profiling.
- HOW WE COLLECT YOUR PERSONALLY IDENTIFIABLE DATA
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.
- 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 firstname.lastname@example.org 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.
- 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.
- 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 email@example.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.
- 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.
- GOVERNING LAW
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.
- 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.
- 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.
- 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.
a. What’s a cookie?
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.
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.
- HOW WE RESPOND TO DO NOT TRACK SIGNALS
At this time, we do not honor Do Not Track signals.
- 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:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
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 email@example.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).
- DATA TRANSFER RISK DISCLOSURE—NOTICE TO NON-US USERS:
For Non-US users, we have requested your specific consent to the following transfers:
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.
- 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).
- CONTACT INFORMATION
Our full contact details are:
Jenna Barwin, 32565-B Golden Lantern Street #129, Dana Point, California 92629.
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