PRIVACY POLICY

 

Effective date: February 4, 2019

Sara Spicer (“us”, “we”, or “our”) operates the http://saraspicer.com/ website (the “Service”). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We understand that security and privacy are important issues for users of our Services. The following Privacy Policy (the “Policy”) describes how we collect, use, share and protect the information that we gather about you when you use of Service.  Please read this Privacy Policy carefully to understand out policies and practices regarding your information and how we will treat it. If you do not agree with our Privacy Policy regarding your information, your choice is not to use our Service.  By using the Service, you consent to the collection, use, and disclosure of your information, which may include Personal Information (defined below), in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from http://saraspicer.com/. Your use of our Services is subject to this Privacy Policy and our Terms of Service.

You must be 18 or older to use our Service. Minors under 18 and at least 13 years of age are only permitted to use our Services through an account owned by a parent or legal guardian with their appropriate permission and under their direct supervision. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for the Service. If you are under 13, please do not attempt to register for the Service or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at  saraspicer.com/

By visiting or using the Service, you will be providing us or allowing us to collect information about you, including Personal Data (defined below) and also personally consent to the collection, use and transfer of your information under the terms of this Privacy Policy.

This Policy may change from time to time (see Changes to this Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

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1. Definitions

• “Service” is the http://saraspicer.com/ website operated by Sara Spicer

• “Personal Data“ means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

• “Usage Data” is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• “Cookies” are small pieces of data stored on your device (computer or mobile device).

• “Data Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

• “Data Processor(s)” (or “Service Provider(s)”) mean any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

• “Data Subject” (or “User”) is any living individual who is using our Service and is the subject of Personal Data.

2. What Information We Collect

We collect several different types of information for various sources and for various purposes as follows:

2.1 Information You Provide to Us

You don’t have to create an account to use our Service. However, by purchasing merchandise, asking to be the first to hear about news, tour dates, and get exclusive deals we may collect a variety of information from you, including personally identifiable information, which is information that can be used to contact or identify you as a natural person (“Personal Data”), including your first and last name, email address, zip code, and date of birth. We may also collect data pertaining to your online transactions, purchase history, and Service usage patterns.


We may use your Personal Data to contact you with newsletters, tour dates, release dates, special offers, exclusive deals, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

If you are paying for merchandise available via the Service, standard payment and billing information is required though that information is shared only with our third-party e-commerce partners, as discussed below.

Depending on which Service you choose to use, additional information may be collected and stored, if necessary in order for us to provide a particular Service. Such information includes:

(iii) demographic information such as age, ethnicity, and gender;

(iv) financial information, such as credit/debit account information, you may provide our third-party e-commerce partners to purchase an item or service;

  (v) transactional information based on your activities via the Service;

  (vi) computer sign-on data, time and date data, statistics on page views, your IP address, your GPS location, the type of computing environment you use, and traffic to and from the Service (including data about you whenever you interact with the Service, such as when you search, click on links, send messages, make comments, replies or queries, and select best replies);

(vii) other technical information or data collected from Website traffic, including IP address and standard web log information and information gathered from cookies, beacons and other mechanisms (see Usage Data and Tracking & Cookie Data);

(viii) supplemental or additional information we may request from you in the event previous information you’ve provided cannot be verified;

  (ix) your content and any other information that you choose to make available via the Service or that other users of the Service share about you;

(x) information that you opened or otherwise interacted with an email and what email you opened or otherwise interacted with; and

  (xi) other information that you voluntarily provide to us.

2.2 Information we collect about you from third parties.

We work with some third party service providers who assist us in managing or providing the Service (e.g., payment processors and companies performing analytic functions) and who collect some of the information described above. These third parties process payment information for us and some third parties provide us analytic data so we can better provide the Service also help us understand how users interact with our content or offerings. We may also collect contextual or demographic data about our users from third parties, in order to more effectively deliver the Service or content in which we think you would be interested. Unless you have been notified otherwise, all information collected through our authorized third party service providers remains governed by security and confidentiality obligations consistent with this Privacy Policy and applicable law.

2.3 Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information about your use of our Service and your orders, including but not limited to your Internet protocol (“IP”) address, which we may also use to establish your geolocation; the type of device and web browser you are using; the version of your operating system (“OS”), the website that led you to our website; the website you visit after leaving our website; the pages you view on our website; the dates and times you access our Service; and information about any orders you place, such as your order identification number, items ordered and the cost of your order. When you use the Service on a mobile platform, we may also collect and record your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), your device name, and your location (based on your IP address). We may also collect information regarding your activity on the Service (both individually and on an aggregate basis) and your interactions with other users of the Service.

2.4 Cookies and Similar Technology

As further described in the Tracking and Cookie Data section below, we use cookies and similar technologies (e.g. web beacons, pixel tags, or other device identifiers) to store login information and recognize you and/or your device(s) on, off, and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools as more fully explained in the Tracking and Cookie Data section below.

3. Why We Collect and How We Use Your Data

How we use your information including your Personal Data, will depend on what Service you use, how you use the Service and the choices you make in your settings. The primary reason we collect information is to provide and improve our Service, to allow us to work with our partners who contract with us to provide marketing services for their products and services, and to provide you with a more customized experience on our Service. The following is a summary of more specific ways we may use your information, including your Personal Data:

3.1 Providing and Maintaining the Service

To facilitate your orders; to respond to your questions or requests; to provide you with news or other information we think may interest you; to communicate with you about other events, promotions, tours, release dates, and/or an goings on about the artist; to communicate to you regarding your orders or requests for information; to provide and maintaining our Service; to provide customer support; to gather analysis or other information to improve our Service; to monitor the usage of our Service; to notify you about changes to the Service; orders or use of our Services or for other informational purposes; to improve our Services; to detect, prevent and address technical issues; to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information; to comply with the law, court order, subpoena or other governmental or administrative order or requirement; for purposes of a sale, acquisition, transfer or bankruptcy; and/or for other account or customer support-related purposes.

For example, we may use your email address to send you a welcome email message when you first register informing you about the Service and reach out to market other events, items, etc., that we believe you might be interested giving your interest in our Service. You may be required to respond to this email in order to validate that you are the owner of the email address associated with the account. If applicable, failure to respond to the email and verify the address within the time stated in the email will cause the account to become inactive. This process is designed to verify the validity of the email address and to help prevent email addresses from being used without permission in the creation of accounts. We may also send you email about periodic service updates, recommended security updates, or surveys related to our Service or other matters. These periodic emails are considered essential to the provision of the Service you have requested. If you unsubscribe from these mailings, we will not be able to provide certain Service to you.


3.2 Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are in the European Union (EU)  and/or the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. That being said, we may process your Personal Data because:

• We need to perform a contract with you


• You have given us permission/consent to do so


• The processing is in our legitimate interests and it’s not overridden by your rights


• To comply with the law

3.3 Marketing and Advertising

As part of our Service, we (including through our third-party service providers or third-party partners) may recommend for your consideration various special offers, services, products, merchandise, events, tours, releases, and other marketing or promotional communications. Accordingly, we may analyze data pertaining to your online transactions, purchase history, and Service usage patterns so that we can make recommendations suited especially to you. We may provide marketing or advertising to you in a variety of ways, including through our Services, via email or on other third-party websites (e.g., using Google Analytics Remarketing or Facebook Pixel).

3.4 Research, Analytics, and Behavioral Remarketing

To analyze how customers/site visitors use our Service; to analyze how customers/site visitors interact with marketing or other communications we send to them; and for other research, analytical and statistical purposes.

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We use third-party marketing or advertising services (e.g., Google Analytics Remarketing and the Facebook Pixel) to serve advertisements on our website and on third-party websites or other media (e.g., social networking platforms). This enables these third parties to target advertisements to you for products and services in which you might be interested. These advertisements may be targeted based on the pages you view on our website or on third-party websites, as well as other information that they may have about you. These third parties may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. We may provide these third-party advertisers with information, including Personal Information, about you, as permitted under our agreements with such third parties.

3.4.1 Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service. Currently, we use Google Analytics Remarketing. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

3.4.2 Behavioral Remarketing

We use the third-party marketing/advertising service Facebook Pixel to serve advertisements on our website and on third-party websites or other media (e.g., social networking platforms). This enables these third parties to target advertisements to you for products and services in which you might be interested. These advertisements may be targeted based on the pages you view on our website or on third-party websites, as well as other information that they may have about you. These third parties may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. We may provide these third-party advertisers with information, including Personal Information, about you, as permitted under our agreements with such third parties.

3.4.3 Opting Out of Online Advertising

You can learn more about interest-based advertising from Facebook by visiting this page: To opt-out from Facebook’s interest-based ads follow these instructions from Facebook available here.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy.

You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members.

You can also opt-out from Facebook and other participating companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or advertisements to you, but it does not mean you will no longer receive any advertising through our website or on other websites.

To opt out from Facebook and other participating companies through the DAA in the USA click here; to opt out of the DAA of Canada click here; and to opt out the European Interactive Digital Advertising Alliance in Europe click here; or opt-out using your mobile device settings.

Please note that even if you opt out, you may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

The service providers we use for online advertising may change. By visiting our website, you accept and consent to our use of Google, Facebook and other services to serve advertisements to you.

3.5 Protecting Rights and Interests

To investigate, protect or defend the rights, safety or property of us, our customers, site users or the public; to investigate or enforce perceived violations of our Terms of Service or this Privacy Policy; as evidence in litigation in which we are involved; and for fraud protection and credit risk reduction purposes.

We also use information, including your Personal Data,  as otherwise described in this Privacy Policy, permitted by law, or as we may notify you.

4. How Your Information, Including Personal Data, is Shared

4.1 Sharing By You

Certain Services offered are social by their very nature, so your participation in such a Service will allow others to see your name and/or username, profile picture, social profile, and any other content you upload or disclose through that profile.

4.2 Sharing By Us

We share your Information with third parties as listed below and as otherwise described elsewhere in this Policy:

4.3 Partners / Third-Party Vendors

One aspect of our business is to provide our partners / third-party vendors information about individuals who might be interested in their products, services or events so they can market directly to those individuals. For example, if you purchase merchandize, request information, or make other requests via the Service, you will enter information in order to receive that information. Similarly, if you register to attend an event, whether it be on-line or in person, you will enter information in order to attend that event. We share that information with our partners / third-party vendors who are offering/sponsoring those events, or helping provide such information so they (on our or on their own behalf) may reach out to you about your interest in the partner’s / third party vendors’ products, services or events or related products, services or events. Unless we tell you differently or you consent otherwise, our partners / third-party vendors do not have any right to use your Information beyond what is necessary to market services, products or events to you. Any uses of your information, including Personal Data, by our partners / third-party vendors will remain governed by security and confidentiality obligations consistent with this Privacy Policy and applicable law.

4.4 Service Providers

We employ and allow third parties to perform tasks on our behalf, such as payment processing, data management and analytics, marketing, advertising, communication and IT services, and we need to share your information, which may include your Personal Data, with them in order for them to provide such products and services. Unless we tell you differently or you consent otherwise, these third party service providers do not have any right to use your information, including your personal data, beyond what is necessary to assist us in providing such products, information, and/or Service. Any uses of your information, including Personal Data, by these third parties will remain governed by security and confidentiality obligations consistent with this Privacy Policy and applicable law.

4.5 Affiliates

Subject to applicable laws, we may share your Information with companies with whom the Company is affiliated or related to (e.g., parent company or subsidiaries), and will require such affiliated or related companies to use the Information solely in accordance with this Policy.

4.6 Business Transfers

We may choose to buy or sell assets. In these types of transactions, customer Information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired or merged, or if we go out of business, enter bankruptcy, or go through some other change of control, Information would be one of the assets transferred to or acquired by a third party.

4.7 Protection of Us and Others

We reserve the right to access, read, preserve, and disclose any information, including personal Data, that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, interests, or safety of us, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

4.8 Aggregated and Anonymized Information

We also may share (within our affiliated entities or with third parties) aggregated or anonymized information that does not explicitly identify you or any individual user of our Service. From time to time, we may provide demographic and statistical information to prospective partners for the purposes of securing advertising and/or for general promotion of the Service. This disclosure will not share any personal information of individual users but is intended to give a broad overview of the Service’s membership.

5. Using Other Sites to Login to our Service

Some users may choose to connect to our Service using third-party account credentials (for example, your Facebook, YouTube, Instagram, Spotify or Twitter accounts). If you choose to access our Service via a third-party account, you understand some of your information from those third-party websites/accounts may be shared with us or the respective third-party platform. Our Service may also provide links to (or links from) third-party websites or services, none of which are governed by this Privacy Policy. To the extent that any linked third-party websites or services you visit are not owned by us, we are not responsible for those websites’ or services’ content or information practices. Your information may also be subject to separate policies of such third-party platform. You should review those policies before providing consent. We strongly encourage you to review the privacy policy of any website or service before providing any personal information. These companies typically use a cookie or third party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit www.networkadvertising.org.

6. Tracking & Cookie Data

We use cookies and similar technologies (e.g. web beacons, pixel tags, or other device identifiers) to store login information and recognize you and/or your device(s) on, off, and across different parts and functions of our Service and devices.

“Cookies” are text files transferred to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are widely used to make websites work more efficiently, recognize your browser or device, improve your user experience, customize features and advertising, and provide reporting information about the Services. Cookies, for example, enable us to keep track of your movement from page to page so you do not get asked for the same information you have already provided us. Cookies also allow you to proceed through many pages of a website quickly and easily without having to authenticate or reprocess each new area you visit.

You can configure your desktop or mobile browser’s settings to reflect your preference to accept or reject cookies, including how to handle third-party cookies (see How Can I Manage Cookies? below).

You can find out more information about cookies at http://www.allaboutcookies.org and http://www.youronlinechoices.eu.

In addition to cookies, there are other similar technologies used by us and elsewhere on the web or in mobile sites or applications. Web beacons, browser storage and plugins and other technologies often work in conjunction with cookies, and may store small amounts of data on your device.

These technologies may be included in our web pages, mobile apps, emails, and other digital content, and include the following:

Web beacons/clear GIFs.  Small graphic images or web programming code called web beacons (also known as “pixel tags” or “clear GIFs”) may be included on the pages of the Website and in email messages we send you.  Web beacons or other similar technologies may be used for a number of purposes, such as to count visitors to the Website, or to count how many particular articles or links posted on the Website were actually viewed.

Mobile Device Identifiers.  Certain mobile service providers uniquely identify mobile devices and we, our Partners or our third party service providers may receive such device information if you access the Website through a mobile device. Certain features on the Website may require collection of mobile phone numbers and we may associate that phone number to mobile device identification information. Additionally, some mobile service providers operate systems that pinpoint the physical location of devices that use their services. Depending on the provider, we, our Partners or our third party service providers may receive this information. The Services may use cookies and other technologies that work in conjunction with cookies (such as SDKs, pixels, tags, or web beacons) to collect and store the Information We automatically collect about our users’ device and use of the Services.

LSOs. We may also use local storage objects (“LSOs”) to store your website preferences and to personalize your visit. LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete or disable the acceptance of LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, please click here. We may use applications, servers and other technology provided by third-party companies, such as Google Analytics, to help us improve our Services, performance and user experiences. These entities may use cookies and information-gathering tools, such as web beacons or LSOs, to perform their services.

While specific types of cookies and technologies may change from time to time as we improve and update the Service, cookies used by the Services generally fall into the categories below:

Each cookies falls into one of the four following categories:

Category

Description

Strictly Necessary Cookies

Strictly necessary cookies (First Party Cookies) are essential as without them We cannot provide many services that you need on the Website. For example, essential cookies help remember your preferences as you move around the Website.

Analytics Cookies

These cookies track information about visits to the Website so that we can make improvements and report our performance. For example: analyze visitor and user behavior so as to provide more relevant content or suggest certain activities. They collect information about how visitors use the Website, which Website the user came from, the number of each user’s visits and how long a user stays on the Website. We might also use analytics cookies to test new ads, pages, or features to see how users react to them.

Performance & Functionality Cookies

During your visit to the Website, cookies are used to remember information you have entered or choices you make (such as your username, language or your region) on the Website. They also store your preferences when personalizing the Website to optimize your use of the Website, for example, your preferred language. These preferences are remembered, through the use of the persistent cookies, and the next time you visit the Website you will not have to set them again.

Advertising or Targeting Cookies

These Third Party Cookies are placed by third party advertising platforms or networks in order to, deliver ads and track ad performance, enable advertising networks to deliver ads that may be relevant to you based upon your activities (this is sometimes called “behavioral” “tracking” or “targeted” advertising) on the Website. They may subsequently use information about your visit to target you with advertising that you may be interested in, on the Website and other websites. For example, these cookies remember which browsers you have visited.

Social Networks

Some technologies help you to interact with social networks you are signed into while using the Services, such as sharing content with the social network, logging in with the social network, and other features you employ with the social network, or that are allowed in the social network’s privacy policy. These may be set and controlled by the social networks, and your preferences with those social networks. You can manage your privacy preferences for these social networks and their tools and widgets via your account with the social network.

The tools may assign or collect unique cookie IDs or other identifiers associated with your browser or device. The tools may collect information while you are using our Service or while they are running in the background of your device.

The information automatically collected may include:

  • Information about your computer, device, browser and operating system, e.g., type, model, or version).
  • Internet protocol (IP) address, which may be used to derive your general geographic area, e.g., city and country.
  • Device identifiers, e.g., mobile advertising IDs.
  • Information about your interactions with the Services, including browsing activities and clickstream data that reflect the content you have accessed, clicked on, or viewed.
  • Information about how you accessed the Services, including details about websites or apps visited immediately before or after accessing a Digital Service.
  • Demographic, interests and household information.

Information about your interactions with email messages and other communications, such as whether you opened or forwarded the email or clicked on links contained in the email.

6.1 Our Own Cookies

The Service uses certain functional, non-persistent cookies to identify you as you use the Service. This helps us and our third-party service providers to provide you with a good experience when you browse the Service and also allows us and our third-party service providers to improve our Service.

We use our own cookies in particular:

• For log-in identification;

• For load distribution;

• To store your language settings; and

• To note that information placed on our Service has been displayed to you – so that on your next visit to the Website it does not need to be displayed again.

We wish to enable you to use our Service in a convenient and individual way. This Service is based on our legitimate interest on the legal basis of Art. 6 sec. 1 lit. f GDPR. Those cookies do not contain any information that, in itself, personally identifies you and do not provide us with access to the rest of your device. We may, however, associate the information contained in cookies with personal information that you have provided to us separately.

We might introduce further types of cookie and/or similar technology from time to time to improve your experience of the Service. If we do so, we shall provide details of any such usage on the Website.

If you would like any further information on the cookies that we use, you can contact us at info@saraspicer.com.

We further use cookies and comparable technologies (e.g. web beacons) of partners for analytical and marketing purposes. This is described more precisely in the following sections.

6.2 Third-Party Cookies

On our Service, our third-party provides use cookies as follows:

Google Analytics

We use Google Analytics’ which Google uses the information shared by websites and apps to deliver our services, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize content and ads you see on Google and on our partners’ Websites and apps. To learn more about our use of Google Analytics and what Google Analytics does, please see How Google Uses Information From Websites or Apps that Use Our Services.

If you do not want your data collected with Google Analytics, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js, analytics.js, and dc.ja) running on websites to prohibit sending information to Google Analytics.

To opt-out of Analytics for the web, visit the Google Analytics opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser.

Updates to your browner or operating system may affect functionality of the opt-out add-on. Learn about managing add-ons for Chrome here. If you are not using Chrome, check directly with the manufacturer of your browser to determine whether add-ons will function properly on the browser version that you are using.

The latest versions of Internet Explorer sometimes load the Google Analytics opt-out add-on after sending data to Google Analytics. Therefore, if you are using Internet Explorer, the add-on will set cookies on your computer. These cookies ensure that any collected data is immediately deleted from the collection server. Please make sure that third party cookies aren’t disabled for your Internet Explorer browser. If you delete your cookies, the add-on will, within a short timeframe, reset these cookies to ensure that your Google Analytics browser add-on remains fully functional.

The Google Analytics opt-out browser add-on does not prevent data from being sent to the Website itself or in other ways to web analytics services.

Learn about how Google Analytics collects, uses, and processes data here.

Learn about the cookies Google Analytics uses here.

PayPal

We use PayPal to process financial transactions made through our Service. PayPal requires cookies to be turned on to log into your PayPal account and to save certain settings. To learn more about PayPal’s cookies go here; to find out how to operate PayPal’s cookies, including turning them on or off, go here and for more information about PayPal’s privacy policies, please review PayPal’s Privacy Statement.

6.3 How You Can Manage Cookies?

You can choose whether or not to accept cookies and other technologies, as explained below. However, you should be aware that disabling cookies may prevent you from enjoying the full functionality of the Services.

Most browsers allow you to change your cookie settings. The “Options” or “Preferences” menu of most browsers detail how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Your browser’s settings may also allow you to disable or delete similar technologies and data used by browser add-ons (such as Flash cookies), for instance by changing the add-on’s settings or clearing browser storage. Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information:

Google Chrome

Internet Explorer

Mozilla Firefox

Safari (Desktop)

Safari (Mobile)

Android Browser

Opera

Opera Mobile

Cloudflare

For other browsers, please consult the documentation that your browser manufacturer provides.

If you only want to limit third party advertising cookies, you can turn off most of these cookies by visiting the following links (but be aware that not all of the companies listed on these sites drop cookies via our Services):

You can also exercise your Website cookie preferences by visiting the TRUSTe preference center by clicking this link: http://preferences-mgr.truste.com/

Browser Controls: You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Websites though your access to some functionality and areas of our Websites may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

Disabling Most Interest Based Advertising: Most advertising networks offer you a way to opt out of Interest Based Advertising. If you would like to find out more information, please visit http://optout.aboutads.info/?c=2&lang=ENor http://www.youronlinechoices.com.

Mobile Advertising: You can opt out of having your mobile advertising identifiers used for certain types of Interest Based Advertising, including those performed by us, by accessing the settings in your Apple or Android mobile device and following the most recent published instructions through the Digital Advertising Alliance’s YourAdChoices. In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads. If you opt out, we will remove all data about you and no further data collection or tracking will occur. The random ID we (or our third party partners) had previously assigned to you will also be removed. This means that if at a later stage, you decide to opt-in, we will not be able to continue and track you using the same ID as before, and you will for all practical purposes be a new user to our system.

For Google Analytics, you can opt-out through Google Ads Settings, Ad Settings for mobile apps, or any other available means (e.g. the NAI’s consumer opt-out listed above). Google also provides a Google Analytics opt-out plug-in for the web.

Please note that even if you opt-out and limit cookies or these third party tracking technologies, they may still collect data and you may still see ads, but they will not be targeted based on information collected through these technologies.

7. Do Not Track and Location Controls

Do Not Track is a privacy preference that users can set in their web browsers. Some Internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. You may be able to set your Internet browser or mobile device to block cookies or other tracking/recording tools, including cookies associated with our websites or Services, or to indicate when a cookie is being set by us.

7.1 Do Not Track

We support the Do Not Track browser setting.  Do Not Track (or DNT) is a preference you can set in your browser to let the websites that you visit know that you do not want them collecting certain information about you.  For information and instructions about how to manage your cookies, refer to your Internet browser’s or mobile device’s technical information.  Further information on how to adjust your cookie preferences through your browser is available at the external, third-party informational website www.allaboutcookies.org. However, it is important to remember that our Service may not function properly if your cookies or location are disabled. 

Since uniform standards for “DNT” signals have not been adopted, we do not currently process or respond to “DNT” signals. We deploy cookies and other technologies on our Service to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.

7.2 Do Not Track in California

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

8. Retention of Data

Sara Spicer will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Sara Spicer will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

We generally retain your information, including Personal Data, as long as reasonably necessary to provide you the Services or to comply with applicable law. However, even after you deactivate your account, we can retain copies of Information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Service, to assist with investigations, to enforce our Terms of Use or other applicable agreements or policies, or to take any other actions consistent with applicable law.

Information you have shared with others (e.g. through comments or other posts) will remain visible after you close your account or delete the information from your own account, and we do not control data that other users copied out of our Service.

9. Where Will Your Information Be Held / Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information. Data transferred will be treated in accordance with this Policy and, where applicable, the EU General Data Protection Regulation.

10. Lawful Basis for Processing

We will only collect and process information about you where we have lawful bases. Lawful bases include consent (where you have given consent); via contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)); to protect vital interest; and when we have “legitimate interests”, which includes direct marketing.

Where we process information based on consent you may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.

Where we rely on contract, we will ask that you agree to the processing of personal data that is necessary for entering into or performance of your contract with us. We provide a voluntary service; you can choose whether or not you want to use the Service. However, if you want to use the Service, you need to agree to our Terms of Use, which set out the contract between the Company and you. As we operate in countries worldwide (including the US) and use technical infrastructure in the US to deliver the Services to you, in accordance with the contract between us, we may need to transfer your Information to the US and to other jurisdictions as necessary to provide the Services.

Where we rely on legitimate interests as a basis for Information processing, you have the right to object. We may process your Information, including personal data, for the purposes of our legitimate interests or for the legitimate interests of third parties including our partners, provided that such processing shall not outweigh your rights and freedoms. For example, we may process your personal Information to:

• Protect you, us, or others from threats (such as security threats or fraud)

• Comply with laws that apply to us

• Enable or administer our business, such as for quality control, consolidated reporting, and customer service

• Manage corporate transactions, such as mergers or acquisitions

• Engage in direct marketing;

• Understand and improve our business or customer relationships generally

• Enable us and our users to connect with each other, view content, express opinions, exchange information, and conduct business

If you have any questions about the lawful bases upon which we collect and use your Information, please contact us at info@saraspicer.com.

11. The Security of Your Information and Personal Data

The security of your information, including Personal Data, is important to us. We maintain reasonable security measures, including administrative, technical, and physical safeguards, to protect your information, including personal Data, from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We endeavor to protect the privacy of your information including your Personal Data we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

12. What Choices You Have

You can always opt not to disclose information or to disable certain tools on your browser or device. However, this may limit your ability to fully utilize the Service.

You may be able to add, update, or delete Information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. Please note that some Information may remain in our records for legitimate business reasons even after your deletion of such Information, such as our analyzing aggregated data regarding past usage of the Service (but not in a manner that would identify you personally). Additionally, through Google’s security settings page, you may revoke consent to the use of API Data related to you that was accessed or stored by the Service pursuant to such consent. Company shall delete all such API Data no later than thirty (30) calendar days following such revocation.

If you don’t want to receive e-mail or other communications from us, you can adjust your email preferences from your account, or opt-out by clicking on the link provided in the emails.

13. EU/EEA Data Subject Rights

Individuals located in certain countries, including the European Union (“EU”) and the European Economic Area (“EEA”), have certain rights related to their personal Information. Subject to any exemptions provided by law, you may have the right to request the following for personal data that we have about you:

Delete

You can ask us to erase or delete all or some of your Personal Information (e.g., if it is no longer necessary to provide Service to you).

Change, Rectify, and/or Correct

You can ask us to change, update or fix your Personal Information in certain cases, particularly if it’s inaccurate.  Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings. If you are unable to perform these actions yourself, please contact us to assist you.

Object to, Limit or Restrict the Use of

You can ask us to stop using /processing all or some of your Personal Information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Information is inaccurate or unlawfully held).

Right of Access and Data Portability

You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine-readable commonly-use form/format.

Restrict

You have the right to request that we restrict the processing of your Personal Information.

Withdraw Consent

You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

Please note that we may ask you to verify your identity before responding to such requests. You may contact us using the contact information below, and we will consider your request in accordance with applicable laws. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

14. Email Communications

From time to time, we may send you emails regarding updates to our websites, mobile applications or products/services, notices about our organization, information about products/services we offer, or promotional offers from third parties that we think may be of interest to you.  If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication.  Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).

15. California Resident Privacy Rights

If you are a California resident, you may request certain information regarding our disclosure of your Information to third parties for their direct marketing purposes during the prior calendar year under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83). You may make one (1) request per calendar year. In your request, please affirm that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at: info@saraspicer.com. Please allow up to thirty (30) days for a response.

16. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

17. Contact Us

If you have any questions about this Privacy Policy, please contact us at info@saraspicer.com