I have tried to make this policy easy to read, and to comply with the EU General Data Protection Regulation in force from May 25, 2018. Most of this stuff sounds a bit scary, but it’s really just the standard data gathering that we’ve been agreeing to in terms and conditions for years… it’s being explained to you better now, is all, and you have more control over it (which is a good thing!). Basically, I will never sell your data, be careless in it’s storage, or be a dick about aggressive or invasive collection. I’m bound though in some cases by the third party services I have to use to bring you the services you want from me, which is what the vast majority of what’s below applies to… For all of that in official terms, read on.
– Lora O’Brien.
1. What Data We Get
We collect certain data from you directly, like information you enter yourself, data about your participation in courses, and data from third-party platforms you connect with through us (eg. Patreon). We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.
Data You Provide to Us
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.
When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:
- Account Data – in order to use certain features (like registering for a class), you may need to create a user account. When you create or update your account, we collect and store the data you provide, like your name and email address (“Account Data”).
- Shared Content – parts of the Services let you interact with other users or share content publicly, including by posting reviews on a class page, asking or answering questions, sending messages to students or instructors, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.
- Course Data – when you enroll in and take courses, we may collect certain data to facilitate your learning experience, including which courses, assignments you’ve started and completed; your exchanges with instructors, essays, answers to questions, and other items submitted to satisfy course requirements.
- Payment Data – if you make purchases, we collect certain data about your purchase (such as your name) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, etc. For security, we do not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
Data About Your Accounts on Other Services
We may have access to basic information through your social media or other online accounts if they are visible to us through third party services (eg. Patreon). If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
Surveys and Review Forms
Communications and Support
The data listed above is stored securely by us and associated with your account.
Data We Collect through Automated Means
When you access the Services we may collect certain data by automated means (honestly, we’re not terribly ‘good’ at this side of marketing, so it’s mostly irrelevant… but just in case!), including:
System Data – technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).
Usage Data – statistics about your interactions with the Services, including pages accessed, time spent on pages or the Service, features used, your search queries, click data, date and time, and other data regarding your use of the Services (“Usage Data”).
Approximate Geographic Data – an approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.
The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.
2. How We Get Data About You
We use tools like cookies, analytics services, and such to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
Cookies and Data Collection Tools
Write Ireland and service providers acting on our behalf (like Google Analytics) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools”) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services.
We use third-party browser and mobile analytics services like Google Analytics, or ConvertKit (email provider) on the Services. These services use Data Collection Tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data, and where the application was downloaded from. We use this data to improve the Services, better understand how the Services perform on different devices, and provide information that may be of interest to you.
We may occasionally use third-party advertising services like Facebook, Instagram, Google’s ad services, or other ad networks and ad servers to deliver advertising about our Services on other websites and applications you use. The ads may be based on things we know about you, like your Usage Data and System Data (as detailed in Section 1), and things that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services, and may be tailored to your interests.
Depending on the types of advertising services we use, they may place cookies or other tracking technologies on your computer, phone, or other device to collect data about your use of our Services, and may access those tracking technologies in order to serve these tailored advertisements to you. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.
When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.
3. What We May Use Your Data For
We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized messaging where you’ve indicated interest, save you from irrelevant messaging, and as required by law or necessary for safety and integrity. The list below mostly covers how third party services (Google etc.) are already using your data – we personally do very little along these lines!
We use the data we collect through your use of the Services to:
- Provide and administer the Services, including to display customized content and facilitate communication with other users
- Process your requests and orders for courses, products, specific services, information, or features
- Communicate with you about your account – responding to your questions and concerns; sending you administrative messages and information, including messages from instructors and teaching assistants, notifications about changes to our Service, and updates to our agreements
- Sending you information about your progress, member discounts, new services, promotions, resource newsletters, and other available resources – paid and free (which you can opt out of at any time)
- Manage your account preferences as directed by you
- Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse
- Request feedback and reviews from you
- Market and administer surveys and promotions
- Learn more about your needs by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers
- Identify unique users across devices
- Tailor advertisements across devices
- Improve our Services and develop new products, services, and features
- Analyze trends and traffic, track purchases, and track usage data
- Advertise the Services on third-party websites and applications
- As required or permitted by law; or as we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.
4. Who We Share Your Data With
We share certain data about you with companies performing services for us, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
With Service Providers, Contractors, and Agents:
We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
With Analytics Services:
As part of our use of third-party analytics tools like Google Analytics, we may share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 1), or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We would only do this to communicate with you in a more effective and customized manner.
To Power Social Media Features:
To Administer Promotions and Surveys:
We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey, which will be clearly stated.
For Security and Legal Compliance:
We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Permitted or required by law;
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Write Ireland, our users, employees, members of the public, or our Services.
We can disclose or use aggregate or de-identified data for any purpose.
With Your Permission:
We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.
Write Ireland takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Write Ireland, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. But we do our absolute best to ensure this. Your password is an important part of any security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact the Service provider with any concerns.
6. Your Rights
You have rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.
Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.
To stop receiving promotional communications from us, you can opt out by using the unsubscribe link at the bottom of EVERY email communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will have to send you occasional transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared. You can manage Adobe’s LSOs through their Website Storage Settings panel.
To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Union, visit the Your Online Choices site. To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page. Make sure to check your Facebook Interests too!
To opt out of allowing Google Analytics, see the Google Analytics Opt-out Browser Add-on. If you have any questions about your data, our use of it, or your rights, contact us at firstname.lastname@example.org.
Accessing, Updating, and Deleting Your Personal Data
You can access and update your personal data that we have collected :
Our Mailing list is stored directly with ConvertKit, who are working to update their data storage in compliance with the GDPR.
To request to access, correct, or delete any personal data we have direct access to, just email email@example.com. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.
Our Policy Concerning Children
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children under 13 (or under 16 in the European Economic Area) should not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.
Parents who believe that we may have collected personal data from a child under those ages can submit a request that it be removed to firstname.lastname@example.org.
7. Updates & Contact Info
If we make a material change to this policy, we’ll notify users via email, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email or postal mail with any questions, concerns, or disputes.
What are cookies?
Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your activities across websites, including on these Services. Cookies also allow us to remember things about your visits, like your preferred language, and to make the site easier to use such as with faster image downloads.
We use both session cookies, which expire after a short time or when you close your browser, and persistent cookies, which remain stored in your browser for a set period of time. We use session cookies to identify you during a single browsing session, like if you log in. We use persistent cookies where we need to identify you over a longer period, like when you request that we keep you signed in.
You can opt out of some of these services through tools like the Google Analytics Opt-out Browser Add-on.
To learn more about targeting and advertising cookies and how you can opt out, visit www.allaboutcookies.org/manage-cookies/index.html, or if you’re located in the European Union, visit the Your Online Choices site at http://youronlinechoices.eu/.
What are my privacy options?
- Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by consulting your browser’s support articles. If you decide to decline cookies, please note that you may not be able to sign in, customize, or use some interactive features in the Services, and your experience will be …. much …. slow…. er….
- Flash cookies operate differently than browser cookies, so your browser’s cookie-management tools may not remove them. To learn more about how to manage Flash cookies, see Adobe’s article on managing flash cookies and Website Storage Settings panel.
- To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Union, visit the Your Online Choices site http://youronlinechoices.eu/. To opt out of Google Analytics’ display advertising or customize Google Display Network ads, visit the Google Ads Settings page.
- For general information about targeting cookies and how to disable them, visit www.allaboutcookies.org.
Updates & Contact Info