Modification Date: May 2, 2018
Effective Date: June 2, 2018
Hi. Christina here. Just like you, I care about the use of my personal information online, so it only seems fair I provide you with our privacy practices at FoodPhotographyClub.com. Unfortunately, different parts of the world now seem to require different disclosures on privacy than others. With this in mind…
I. If You are Located In the EU
A. What Personal Data Do We Collect From You?
Personal data is information that can be used to identify you such as your name, IP address, and email address. We collect personal data from you in a number of ways including:
(1) Waiting List: Your email address and name if you wish to be put on a waitlist to join the Club.
(2) Membership: Your name and billing information including your billing address if you pay for your membership by credit card number or your PayPal address if you pay through that system.
(3) Forum Participation: If you join the Club and decide to participate in our forum where members can communicate with each other – The Club Room – we will collect your username and any information you voluntarily add to your profile. We will also collect and hold any personal data you post on the forum.
(4) Customer Service: Your name and email address if you submit questions to us.
(5) Feedback On Your Work: Your name and email address if you request feedback from us for your photos or projects.
B. What Is The Purpose of Processing Your Personal Data?
We collect the information above for the following purposes. Each entry corresponds to the numbered list above.
(1) Waiting List: Your email address and name are collected so we can email you information about the Club.
(2) Membership: We use your name and billing information to process your membership payment each month.
(3) Forum Participation: If you participate in our forum, we use the personal data you provide to facilitate communications between you and others in The Club Room.
(4) Customer Service: We have a legitimate interest in collecting your information so we can respond to you.
(5) Feedback On Your Work: When you ask for feedback, we use the name and address you submit to respond to you with our feedback.
C. What Legal Basis Do We Have For Collecting and Processing Your Information?
Websites must have a legal basis for collecting information from individuals located in the European Union. Our legal basis for each of the ways we collect information from you is as follows. Please note where consent forms the basis, you can withdraw consent at any time by contacting us at firstname.lastname@example.org or opting out of any email message using the “unsubscribe” link.
(1) Waiting List: Joining the waiting list to become a member: We will obtain your consent first.
(2) Membership: Paying the initial and monthly membership fee: Your data is collected as part of an allowed legal contractual transaction.
(3) Forum Participation: We have a legitimate interest in collecting your personal data to facilitate communications.
(4) Customer Service: Submit questions to us: We have a legitimate interest in collecting your information so we can respond to you. Our processing of your information will provide you with answers to queries without any undue harm to your privacy.
(5) Feedback On Your Work: We have a legitimate interest in collecting your information so we can respond to you. Our processing of your information will provide you with feedback on your work without any undue harm to your privacy.
“Legitimate interests” for processing your personal information exist where you submit the information with an expectation that it will be processed and there is no undue impact on you. If you disagree or have questions, please contact us at email@example.com and we will cease the processing of your data under this legal basis.
D. Who Has Access To The Data We Collect?
We process and access to the data we collect from you. However, we use third parties to provide us with a variety of services for the Club including the following categories of recipients: payment processors, content management system, video service providers, forum software providers, consent software providers, analytics providers, and services to send our email messages. These third parties must comply with the European regulations as well and are prohibited from utilizing, sharing or retaining your personal data for any purpose other than providing us services we have contracted for unless any alternative use is first approved.
E. Cookies and Similar Technologies
F. How Long Do We Keep Your Data?
We keep your personal data for different periods of time depending on the reason it was gathered in the first place.
(1) Waiting List: We will keep your data for 24 months although you may opt out of our waiting list using the unsubscribe link in any message.
(2) Membership: Paying the initial and monthly membership fee: We will keep this data for as long as you remain a member since we bill you monthly. Once your membership ends, we will keep this data for four years for our tax records.
(3) Forum Participation: We believe in free speech and the flow of data. We do not intend on voluntarily erasing any forum posts ever. However, you may delete profile information at any time or request we “erase” content you’ve uploaded to The Club Room.
(4) Customer Service: Submit questions to use: We will maintain this data for five years to cover the period of the statute of limitations for any potential legal claims that may be made regarding the subject matter of the question and answer.
(5) Feedback On Your Work: We will maintain this data for five years to cover the period of the statute of limitations for any potential legal claims that may be made regarding the subject matter of the question and answer.
If a legal claim arises involving your data, we will store and disclose that data until the matter has resolved.
G. Your Right To Ask For Corrections, Erasure, And Export Of Your Data
We want you to have control over your data. You have the right to see all the data we have for you, ask for the corrections to the data, ask us to erase the data, object to how we use your data, ask that the data be exported, and ask that we stop automatically processing the data in particular manners. Although we have certain rights to limit your control of data, we believe it is YOUR data so we will liberally comply with your requests whenever possible. We are not a data mining company trying to monetize your personal information. To exercise any of these rights, please contact us at firstname.lastname@example.org.
H. Your Right To Withdraw Consent
Although this is mentioned above, we want to emphasize that wherever we’ve asked for your consent to collect or process your personal data, you have the right to withdraw that consent. You can reach us with a request at email@example.com. If you receive email messages from us, you can use the “unsubscribe” link in each message to withdraw consent and stop the mailings.
I. Do We Transfer Your Data To Third Countries?
No. We are located in the United States. Your data is collected and held here.
J. Privacy Concerns, Contacting Us, Complaints.
You can contact us with any questions or requests you have about these policies or your personal data at firstname.lastname@example.org. Although we are not required to designate a data protection officer pursuant to the General Data Protection Regulation given our small size and data processing activities, you can contact Christina Peters at the email address above. If, after contacting us, you feel a privacy issue has not be resolved, you have the right to file a complaint with a Supervisory Authority such as the Data Protection Commissioner of Ireland.
Representative: Christina Peters
Merseyside Productions Inc. dba Food Photography Club
2110 Artesia Blvd. #697
Redondo Beach, CA 90278
You can contact us by sending a message to email@example.com or correspondence to: Merseyside Productions Inc. dba Food Photography Club, 2110 Artesia Blvd. #697, Redondo Beach, CA 90278
II. For Our Friends Located In California
A. Do Not Track Signals.
Pursuant to the California Online Privacy Protection Act, we hereby disclose that we do not currently honor “do not track” signals issued by browsers or other third party sources.
B. California Eraser Law.
If you are an individual under 18 and have provided personal information or content to us in some manner, you have the right to request the deletion of that information pursuant to the “California Eraser Law.” Contact us to make such a request at firstname.lastname@example.org
III. For All Our Valued Friends Regardless of Location
B. Legal Disclosures of Personal Information.
We may process, store, and disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us, (2) protect and defend our rights or property or (3) act under exigent circumstances to protect the safety of the public or users of the site.
C. DMCA Disclosures
We comply with the Digital Millennium Copyright Act of 1998. As part of the compliance process, we may be required to disclose whatever information we have for you to a copyright holder who has submitted a complaint to us.
D. Public Comments.
You may leave comments on forum posts. Please remember that any information you provide is not private. The information can be viewed by anyone online including family, friends, the media, investigators, and potential employers conducting background checks.
E. Third Party Websites.
We link to other sites, but please keep in mind that we do not control the privacy policies of those sites. Make sure to review the policies of any such sites before providing your personal information.
F. Sale of Business
Should we sell this site or our business, your personal information will be an asset transferred to the new owner.