Shonali Burke Consulting, Inc., (“we”, “us”, “our,” and “SBC”), respects the privacy of visitors to our website, accessible at the domain socialprvirtuoso.com. Through socialprvirtuoso.com and its associated classes, online groups, or communities hosted on Facebook (collectively, the “Site”), visitors, customers, and any other users of the site, may access articles and other material regarding social PR and purchase online classes related to social PR (the “Service”).
INFORMATION YOU VOLUNTARILY PROVIDE TO US
Your payment information.
We collect payment information associated with your Account but we do not store payment information on our servers, temporarily or otherwise. When you provide your payment information on our online forms, your payment information is directly communicated to and processed via our e-commerce software providers without passing through our servers. Our e-commerce vendors are responsible for processing and storing your information in accordance with all applicable laws and regulations.
Online Community Interaction and User Content.
As part of the Site, we operate several online groups and communities through Facebook, and other social media services to allow users to discuss course materials and other topics related to social PR. Through these groups, Site users will have the opportunity to initiate discussions, ask or answer questions, or post comments in response to other users. Excepting “private” account information, which is defined and secured by Facebook, or other social media platforms, not SBC, any information that a user chooses to provide on these platforms that is viewable by others, whether it is a comment, a post, a message in response to anther user, or even a username, avatar, or signature is considered “User Content.”
Please be aware that any User Content you choose to post on the Site and associated platforms will be viewable by other users who have created accounts with the Site and who have access to these platforms. We are not responsible for the third-party use or disclosure of any information or Personal Information that you choose to post on the online groups or communities associated with the Site. If you voluntarily post your Personal Information in a public forum or in a manner that is visible to other users, we cannot control how other users or third parties, who are not bound by the terms of this Policy, will process your information. Any User Content that you choose to post on the Site or on the third party platforms that host SBC’s online communities, such as Facebook, are published and transmitted to others at your own risk.
As part of our operation of the online groups and communities, we may collect the Personal Information that you voluntarily provide to us or otherwise publish through Facebook, which may include your name, email address, or social media profile information. Additionally, we may collect any User Content you post on the online communities. We use this information to track the discussions and activity levels of the communities, interact and communicate with you, and otherwise maintain and improve the Site and Services. While we do collect the information you voluntarily provide on the online communities, we do not have access to your private Facebook account information or information that you have not made publicly available through Facebook. We are not responsible for the privacy and security of your Facebook account, or for Facebook’s privacy practices.
INFORMATION WE COLLECT VIA TECHNOLOGY
In addition to the information that you choose to voluntarily provide, as you navigate and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and Site usage patterns, including: (a) details of your visits to the Site, including traffic data, location data, your search queries on the Site, communication data, and the resources that you access and use on the Site; (b) information about your computer and internet connection, including your IP address, operating system, and browser type; (c) information about how you were referred to the Site or navigate from the Site, such as the referring URL, requested URL, and timestamp information; and (d) information relating to advertisements, such as data collected by cookies created by Youtube, Facebook, Linkedin, and other social media and software developers that are designed to determine which types of ads to display to visitors of websites that have enabled advertisements, to keep track of which videos or advertisements have already been displayed to you on websites that have enabled advertisements, and to track visitors across devices and marketing channels via a unique device ID.
The information we collect automatically is typically statistical or aggregate data that is not Personal Information nor capable of identifying a particular device or individual. Collecting and processing such statistical data helps us improve our Website and deliver a better and more personalized service, including enabling us to: estimate our audience size and usage patterns, optimize the Site, and monitor and maintain the security of the Site.
While the data collected via automatic data collection technologies is generally collected in the aggregate or in a statistical form, some of the data that is collected is Personal Information (such as unique device IDs, which identify a specific device, though not the name or other information about the owner of the device), and some of the data may be maintained or associated with Personal Information. Collecting and processing such information allows us to provide important services and Site functionality, and to otherwise enhance your experience with the Site, including: storing information about your preferences; allowing us to customize our Website according to your particular interests; optimizing your searches and queries; delivering information and marketing materials that have been particularized to your interests, and recognizing you when you return to our Website.
We also use data collection technologies to collect and track your IP address. An “IP Address” is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP address stays the same from browser session to browser session. However, if you use a consumer internet access provider, your IP address probably varies from session to session. We track IP addresses in conjunction with session cookies to analyze our web page flow, for fraud detection purposes, and to maintain the security of your account and of the Site.
To enable to you to better understand how we collect and process information, we have provided information regarding the technologies we utilize for automatic data collection:
“Cookies” are small lines of text that a website sends to your computer’s hard drive while you are viewing a website. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until they expire or until you delete them) to provide you with a more personal and interactive experience on the Site. Persistent cookies can be removed by following the help file directions on your internet browser.
Your browser has options to accept, reject, or provide you with notice when a cookie is sent. Please note, however, that if you choose to disable cookies, some areas of the Site may lose certain functionalities or cease to work properly.
In addition to cookies, pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that allow us to count users who have visited certain pages, opened an e-mail, and for other related statistical purposes (for example, recording the popularity of certain website content and verifying system and server integrity). An invisible pixel is a tiny, 1x1 image that is loaded when you visit a Site, but instead of calling up an image, it causes a cookie or application to be downloaded.
HOW YOUR INFORMATION IS USED
We use the Personal Information we collect to fulfill orders for Services, process and complete any requests you make regarding the Site or Services—including requests to create accounts or receive email communications regarding products, blog posts, and newsletters—and to manage and maintain any accounts you have created. As part of processing and fulfilling your orders for Services, our vendors will use your Personal Information to process your payment as authorized by you during the checkout process and to communicate with you regarding the Services you have purchased.
We also use the information we collect from you via cookies and other technological means to track and implement your account settings and preferences from session to session. We may also use the information we collect to determine the interests and preferences of persons who use your device; identify content that may be of specific interest to such persons; and deliver information, product or service offers, or other content specific to such persons’ interests via targeted advertisements on websites or applications being viewed on the device.
When you create an Account, you may be added to our mailing list to receive information or direct marketing from us relating to the Service or similar services that we believe might be of interest to you. If you receive direct marketing from us, you can opt out at any time by following the instructions included in every email sent to you via the “Unsubscribe” link, or by sending a request to opt out of promotional email communications to email@example.com. We respect your choice and will stop sending you promotional emails once you unsubscribe. Please note, however, that you may not opt out of non-promotional communications from us, including communications confirming successful order placements, communications sent for customer service purposes, notifications regarding important Site or policy changes, communications providing important security or data breach information, and communications containing other significant information related to your Personal Information for as long as it is retained by us.
We may create Anonymous Information records from Personal Information by excluding information (such as your name, IP address, or device ID) that would allow someone to identify a specific individual or device. We may use this Anonymous Information to analyze request patterns and improve the Site and our performance of services offered through the Site. In addition, we may create and use aggregate or statistical information that is not traceable to any particular individual to improve the quality and design of the Website and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends. We reserve the right to use and disclose anonymous or aggregate information to third parties in our discretion.
Based on the preferences that you communicate to us, and based on information we have collected regarding the topics you are interested in, we may perform limited, automated decision-making processes on your information to determine what mailing lists to tag in association with your account. We use these tags to determine which events you might be interested in attending; whether you might be interested in one of our resources, services, or blog posts; and to otherwise provide content to you in response to your expressed preferences. We will never sell or provide to unaffiliated third-parties information about you that is determined through our automated decision-making processes. Nor will we use our automatic decision-making processes to send information to you that is contrary to your expressed preferences.
While we will sometimes request your consent before using your Personal Information, there are many additional legitimate and lawful purposes for which we may collect and use your Personal Information without your consent. For more information, please see the see section titled “Notice Regarding Requested Consents,” below.
OUR DISCLOSURE POLICIES
We may share Anonymous Information for any legitimate business purpose allowed under the applicable laws and regulations without notification or consent.
We will share your Personal Information with employees, consultants, affiliates, or other third party businesses or persons for the purpose of processing your information on our behalf, including processing relating to fulfilling your orders, processing payments relating to your orders, and maintaining and securing our business records. These trusted parties agree to keep your Personal Information confidential, and your personal information will never be shared with unrelated third parties. We will not share your Personal Information with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you have the ability to opt-in or opt-out.
We have taken certain organizational and technological security measures to secure your personal information, described in the “Security” section below, and we require at least the same degree of organizational and technological security to be used by our employees, consultants, affiliates, and third party businesses or persons involved in processing Personal Information. If we disclose your Personal Information as identified in this section, we agree to be liable for violations of your privacy rights by the third parties to which your Personal Information was disclosed.
At this time we do not knowingly transfer your information across international borders. In the future, if we decide to transfer your information across international borders, we will use appropriate methods to transmit your information in accordance with all applicable laws and regulations.
In certain circumstances, we may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
While we may request your consent to use or share your Personal Information to fulfill or perform services regarding your orders and requests, we may also use or share your Personal Information without your consent for any legitimate purpose as allowed under the applicable laws and regulations (see section titled “Notice Regarding Requested Consents,” below), including fulfilling contractual obligations to you, enforcing the Terms of Service, or bringing or defending against legal claims.
We take reasonable technical and organizational precautions, in addition to following industry best practices, to protect your information against loss, misuse, alteration, disclosure, unauthorized access, or destruction.
We make use of Secure Sockets Layer (SSL) technology and keeps sensitive details stored in an encrypted format in our database. We have also implemented other industry-standard electronic means of protecting your Personal Information including storing your Personal Information behind a computer firewall, which is a barrier designed to prevent outsiders from accessing our servers.
In addition to our technical and organizational security precautions, when you create an account, you must designate a password to secure your account information. It is important that you protect against unauthorized access to your password and to your computer by logging off once you have finished using a shared computer or device.
Even though we have taken significant steps to ensure that your Personal Information is not intercepted, accessed, used, or disclosed to or by unauthorized persons, you should know that we cannot eliminate security risks associated with Personal Information.
YOUR RIGHTS REGARDING YOUR INFORMATION
We respect your privacy and want you to be informed of, and in control of, how your Personal Information is used. To exercise any of the rights described in this section, please contact our privacy officer at firstname.lastname@example.org using the procedure described in the “Personal Information Request Submissions” section, below.
Subject to local law, you can control your Personal Information in the following ways:
- You can request access to your Personal Information and obtain a copy of all Personal Information about you in our possession;
• You can correct any errors in your Personal Information, or notify us of any changes to your Personal Information;
• In certain situations, you can request that we erase, block, or restrict access to your Personal Information;
• In certain situations, you can object to the particular ways in which we are using your Personal Information; and
• In certain situations, you can also request that we send your Personal Information to a third party.
We will take all reasonable steps to ensure that your Personal Information is handled according to your wishes.
NOTICE REGARDING REQUESTED CONSENTS
You are entitled to withdraw that consent at any time. If you revoke your consent, you will not be penalized or prejudiced for that revocation.
These uses, among others, may include:
- Complying with legal obligations, for example, tax, employment, and other laws or regulations;
2. Fulfilling our contractual obligations to you;
3. Furthering our legitimate business interests and purposes, whether performed by us or a third party, so long as that purpose does not override your fundamental rights and freedoms;
4. Preventing fraud;
5. For internal administrative purposes, whether your data is maintained internally or shared with our subsidiaries and affiliates, franchisees, or third-party contractors for this purpose;
6. Ensuring network and information security;
7. Establishing, exercising, or defending against any legal claims; or
8. Using your Personal Information in accordance with any valid consents you have given.
If we collect, retain, or use your Personal Information based on a legitimate interest or the public interest, as described above, you may have the right to object at any time to that use of your Personal Information if your local law gives you that right.
NOTICE REGARDING CHILDREN
We do not intentionally gather Personal Information about visitors who are under the age of 18, and you must be at least 18 years or older to create an account or register to use the Site. If you believe that we might have any Personal Information from a child under 18, please contact us using the information in the “Contact Us” section, below.
NOTICE REGARDING CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits users of the Website who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail with “California Privacy Rights” in the subject line to email@example.com or contact us via the information provided in the “Contact Us” section, below.
LINKS TO OTHER SITES
311 Timberwood Avenue
Silver Spring, MD 20901
Attn: Privacy Officer
Effective Date: September 11, 2018