PRIVACY POLICY

This policy was last updated on November 11, 2020

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when purchasing a membership, individual digital content, or a model product.

This website is not intended for children, and we do not knowingly collect data relating to children. You must read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when collecting or processing personal data about you to be fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER
Casey Anne Moon is the controller and responsible for your personal data (collectively referred to as “Model,” “we,” “us,” or “our” in this privacy policy). We have appointed a data privacy manager responsible for overseeing questions concerning this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Casey Anne Moon
Email address: Casey@CaseyAnneMoon.Com

If you reside in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. If you reside within the EEA, you have the right to make a complaint at any time to the appropriate supervisory authority for your country of residence. If you reside outside the EEA, we will apply your legal rights as applicable to the data laws in the jurisdiction you are in. However, we would appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on November 12, 2019. Historic versions can be obtained by contacting us. The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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

THE DATA WE COLLECT ABOUT YOU
“Personal data” or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped as follows:

“Identity Data”

Which includes a username or similar identifier.

“Contact Data”

Which includes email addresses.

“Financial Data”

Which includes payment card details. Our payment processor stores all payment data, and you should review its privacy policies and contact the payment processor directly to respond to your questions.

“Transaction Data”

Which includes details about payments from you and other details of products and services you have purchased from us.

“Technical Data”

Which includes internet protocol (IP) address, cookie ID, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

“Profile Data”

Which includes your username and password, purchases, or orders made by you, your interests, preferences, feedback, and survey responses.

“Usage Data”

Which includes information about how you use our website, products, and services, including the full Uniform Resource Locators (URLs); click-stream to, through, and from our website (including date and time); the content you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.

“Marketing and Communications Data”

This includes your preferences in receiving marketing from our third parties and us and your communication preferences.

“Aggregated Data”

Which includes statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data to directly or indirectly identify you, we treat the combined data as personal data used per this privacy policy.

“Special Categories of Personal Data”

Which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health, or criminal convictions and offenses.

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you, including through:

Direct interactions
You may give us your Identity, Contact, and Financial Data by filling in forms or corresponding with us by email or otherwise. This includes the personal data you provide when you:

Apply for our products or services | Create an account on our website | Subscribe to our service | Request marketing to be sent to you | Enter a competition, promotion, or survey | Give us feedback or contact us.

Automated technologies or interactions
As you interact with our website, we will automatically collect “Technical and Usage Data” about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical and Usage Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources
We will receive personal data about you from various third parties.

“Technical Data”

Gathered from analytics providers such as Google based outside the EU;

Affiliates participating in our affiliate marketing program based inside and

outside the EU; and search information providers such as Google based outside the EU.

“Identity, Contact, and Transaction Data”

Gathered from providers of technical, payment, and delivery services.

“Identity, Contact, and Technical Data”

Gathered from providers of customer support services.

HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract, we are about to enter into or have entered into with you, where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, and where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose of using your data. Please contact us if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below.

Purpose

Activity

Type of Data

Lawful Processing Basis

Registration

New Customer

A / B

Contract Performance

Order Process and Delivery

Payments/Fees

A / B / C / D

Debt Recovery

Payment Processing

Collection/Recovery

A / C / D / E

Debt Recovery

Term/Policy Changes

Notification

A / B / E

Contract Performance

Inquiry

Review/Survey

A / B / E / F

Managing Interests

Participation

Prize/Competition

A / B / E / F

Managing Interests

Administration

Analytic/Support

A / B / F / G / H

Technical

Troubleshooting/Support

Support

A / B / E / F / G / H

Technical/Security

Maintenance/Testing

Support

A / B / E / F / G / H

Security

Reporting

Hosting

A / B / F / G / H

Fraud/ Legal Obligation

Content Delivery

Advertisement

A / B / E / G / H

Managing Interests

Data Analysis

Advertisement

G / H

Managing Interests

Service Recommendations

Advertisement

A / B / E / F / G / H

Managing Interests

 
Type of Data
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Profile (g) Usage (h) Technical

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING
We will get your express opt-in consent before sharing your personal data with any third party for marketing purposes.

OPTING OUT
You can ask third parties or us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences by following the opt-out links on any marketing messages sent to you or by contacting us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us due to a product/service purchase, product/service experience, or other transactions. 

COOKIES
You can set your browser to refuse all or some browser cookies or alert you when websites set or access cookies. Please note that some parts of this website may become inaccessible or not function properly if you disable or refuse cookies. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to explain how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis, which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes stated in the table (Purposes for which we will use your personal data) above. External Third Parties as set out in the Glossary.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it per the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and per our instructions.

INTERNATIONAL TRANSFERS
Many of our external third parties are outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

We use providers based in the US; we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU–US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Also, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put procedures to deal with any suspected personal data breach and notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will you use my personal data?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation regarding our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for seven years after they cease being customers for tax purposes.

You can ask us to delete your data in some circumstances: see Your legal rights below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights
Under certain circumstances, you have rights under data protection laws concerning your personal data. You have the right to request access to, to the correction of, for the erasure of, for restriction of, the transfer of, to the objection of the processing of, and/or the right to withdraw consent of your personal data. Please contact us if you wish to exercise any of these rights.

No fee is usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information concerning your request to speed up our response.

Time limit to respond.
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or have made many requests. In this case, we will notify you and keep you updated.

Your California Privacy Rights
If you are a California resident, you are granted specific rights regarding access to your personal data. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the name and addresses of all third parties with which we shared personal data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided above.

Do Not Track Policy
Do Not Track (“DNT”) is a privacy preference you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect, and that is why we provide you the ability to opt-out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com. Please note that DNT is not effective, according to Gizmodo, as of October 2018.

GLOSSARY

Legitimate Interest
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you regarding specific activities by contacting us.

Performance of Contract
“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply With A Legal Obligation
“Comply With A Legal Obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES AND EXTERNAL THIRD PARTIES

Compliance with Laws
We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Right
We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Vendors, Consultants, and Other Third-Party Service Providers
We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to that information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data about how you interact with the Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. For example, we use Google Analytics to understand how our customers use the website (you can read more about how Google uses your personal data at Google Privacy Policy. You can also file Google Analytics Opt-Out.

Affiliates
We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data
Commonly known as a “data subject access request.” This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.

Request correction of the personal data that we hold about you
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be relayed to you, if applicable, at the time of your request.

Object to processing of your personal data
We rely on a legitimate interest (or those of a third party), and there is something about your particular situation, which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.

Request restriction of processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy, where our use of the data is unlawful, but you do not want us to erase it, where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims, or you object to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or a third party
We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information, which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data

However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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This website was last updated: November 2020