Privacy & Your Data

PRIVACY & COOKIE POLICY: A NOVEL by Dielle

This entertaining reading discloses the privacy practices for DielleCiesco.com and TranquilLivingTribe.WildApricot.org and pertains to information collected by me to serve you including:

  1. What kind of personally identifiable information is collected from you through the web site, how it is used and with whom it may be shared.
  2. What choices are available to you regarding the use of your data.
  3. The security procedures in place to protect the misuse of your information.
  4. How you can correct any inaccuracies in the information.
  5. Other GDPR stuff.

DielleCiesco.com may change this policy from time to time by updating this page. This particular Pulitzer-worthy version is effective from May 8, 2020.

WHAT I COLLECT

CONTACT PAGE

You are free to use the contact page to contact me. By using the contact form, provided by WPForms Lite plugin, you are consenting to have the information you relay transmitted, processed, and stored on my servers and/or in theemail client(s). In fact, it says so right on the page when you submit. It collects only your name and email for this purpose and uses it for no other purpose than responding to your comments or questions.

MAILING LIST

Likewise, subscription to my mailing list(s) is completely voluntary and by consent and managed through our GDPR compliant partner, MailerLite. We do not store the information collected by MailerLite on our website or locally. Learn more about MailerLite’s privacy policies.

EMAIL

Incoming email is processed through our domain server (see Data Retention below for more info) and the Post SMPT plugin which logs and records only the last 20 emails in our database and makes it easy for me to delete everything. Replies and ongoing communication is processed via ProtonMail which is an encrypted email service.

OTHER PLUGINS

Other WordPress plugins that affect user data are related to security or GDPR compliance. For example, I use a backup plugin to save my website from time to time, intermittently, for example before any big changes are made to the website. This would freeze certain information within the database onto the backup that would otherwise be purged (see Data Retention below for more info.). I also use a security plugin to protect this site from attacks which monitors IP addresses in real-time and logs them. These logs are set to be automatically deleted after 30 days.

PAPERWORK

Local client intake forms and/or sign-in sheets are not stored online. They are maintained locally on the office computer or on paper. For Tranquil Living Tribe members, online intake forms are stored in the Wild Apricot data base on your membership profile.

PAYMENTS
Any payments made via the website are managed either via Paypal or Stripe, both GDPR compliant. I do not store the information collected by Paypal (or Stripe) on either the website or locally. You should refer to Paypal’s policies or Stripe’s policies regarding your data.

INVOICELY
I use the website Invoicely to create and send invoices to private clients. Invoicely stores this information on their servers. This information will include your name and email address and may include your home address and phone number. I also keep a copy of each invoice on my computer for tax purposes. Learn more about Invoicely’s Privacy Policy.

What I do with the information gathered
Any information gathered is the bare minimum I need to provide you the service you’ve requested which may include:

  • Internal record keeping.
  • Servicing your membership, if applicable.
  • Promotional email about new classes, events, special offers or other information which you may find interesting using the email address which you have provided. This may include updates to this entertaining privacy policy or terms and conditions.
  • I may need to contact you by email, phone, or mail (for example, to resolve technical issues, to provide customer service, or to notify you of any data breaches in compliance with GDPR).

COOKIES

At DielleCiesco.com, we love cookies…chocolate chip, macadamia nut, ginger snap, oatmeal. Sadly, this has nothing to do with those kinds of cookies. Sorry! These are teeny text files placed on your machine for one of three purposes: Necessity, Performance, or Functionality. This site uses cookies for one of those three reasons…none of them nefarious and creepy…unlike the big boys that surveille and manipulate your every move for in the name of advertising. When it comes to that scale of consumerism, we prefer an actual cookie.

As a rule, cookies will make your browsing experience better, as things will work as they should. However, you may prefer to disable cookies altogether via your browser options. (I do!) May I suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers? Of course, you can also choose not to use this site, but then you’d miss out on all the cool stuff that’s here.

What’s a cookie?

Cookies are teeny text files placed on your machine when you visit this site. Those from this site serve one of three purposes:

  1. Strictly Necessary – the site won’t work without them
  2. Performance – helps us understand how visitors use the site and/or helps us improve it
  3. Functionality- improves how the site works and/or adds personalized glitz for service
  4. Marketing

What cookies do we use?

This site uses cookies for one of those three reasons…none of them nefarious and creepy…unlike the big boys that surveille and manipulate your every move  in the name of advertising.

Type 1

Type 2

PHPSESSID (session cookie)
wfwaf-authcookie-(hash) (security-related)
wfCBLBypass (security-related)

Type 3

_stripe_sid (Stripe)
_stripe_mid (Stipe)
_cfduid (Mailerlite)
viewed_cookie_policy
NID (Google recaptcha)
googtrans (Google translator)
GPS (youtube)
PREF (youtube)
VISITOR_INFO1 (youtube)
VSC (youtube)

About 3rd Party Cookies

3rd party services such as MailerLite, Google, Youtube, Wild Apricot and Stripe employ their own cookies as a result of this site using their services. So when you subscribe to our newsletter or watch any of our videos, for example, you’re accepting those cookies. That seems fair. We don’t have much say in that matter. However, we’ve done away with using Google Analytics as a performance and target cookie. Bad! Bad cookie!

That doesn’t mean that other third parties aren’t planting cookies on your machine. If you click a link on this website that takes you to an outside site, that site may employ 3rd party cookies. This site has no control over another site’s cookie usage.

About 4th Party Cookies

There are no Type 4 cookies used on this site. When it comes to this scale of consumerism, we prefer an actual cookie.

Refusing Cookies

As a rule, cookies will make your browsing experience better, as things will work as they should. However, you may prefer to disable cookies altogether via your browser options. (I do!) May I suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers? Of course, you can also choose not to use this site, but then you’d miss out on all the cool stuff that’s here.

Now then, you’ve earned yourself the kind of cookie you can eat!

SHARIN
G

I don’t share anything with anybody. I’m selfish that way. I like to keep you to myself. As previously mentioned, Paypal (or Stripe) processes all our payments. They are GDPR compliant and don’t retain, share, store or use personally identifiable information for any secondary purposes beyond filling your order. Likewise, when I partner with other parties to provide specific services to you, say, a newsletter through Mailerlite, I may share names, or other contact information that is necessary for the third party to provide those services. Those parties are not allowed to use personally identifiable information except for the purpose of providing these services.

COMMENTS, FORUMS, GROUPS & PAGES

Comments are disabled here. But please remember that comments you may post to blogs, on forums, on groups or pages that are hosted by DielleCiesco.com or supplementary sites will be visible to others. Some such platforms may be public and viewable by anyone, such as posts to outside blogs and on Facebook pages (and we’re all aware now of our unbelievable treasure trove of personal histories making money for Facebook!) Others will be only be viewable by other members of our closed Facebook groups. DielleCiesco.com cannot control who does or doesn’t see information (such as your identity) that you may share under these circumstances.

DATE RETENTION

Nobody likes retaining water. Thanks to GDPR, nobody likes retaining data either. Basically, I only keep what I have to. Emails that come through my hosting service are stored on InMotion servers which are purged at least twice a year. Site backups are created intermittently and the two most recent backups made are stored in house. Paperwork (factures, invoices, sign-in sheets) are kept for 10 years in accordance with taxation requirements. Lapsed memberships are archived and then deleted at regular intervals. Intake forms and other client documents will be purged if you have relocated or stopped taking classes in the last 12 months. (Was it something I said?)

YOUR RIGHTS TO ACCESS & CONTROL

Can you feel the power? You have a right to inquire about your personal data that may be stored with me. You also have a right to request that information be updated and/or vaporized…I mean, deleted. You may also opt out of any future contacts from me at any time, tho’ I can’t imagine why you’d want to! You can exercise these rights by contacting me via email or by phone at 1-571-494-1967 in the USA or +33 (0)783611432 in France…or just call and we’ll have a nice chat.

SECURITY

This site is accessible via HTTP and HTTPS. Please use the HTTPS for your own sake! Precautions to protect stored information are managed with recommended WordPress security measures and various password protections. I also protect your information offline. If I had an employee other than myself, he’d only have access to the information needed to do his job (for example, billing or customer service). Actually, my accountant might see your invoices. The computers/servers and paperwork on which I store your personally identifiable information are kept in a secure environment. Passwords that I store are encrypted.

In compliance with GDPR, you will be notified within 72 hours in the event of a data breach of the website and/or storage systems including my email clients which may result in the vulnerability of your name and email address. Obviously, this only applies to those who have shared personal data that would still be stored in our database at the time of breach.

LINKS

This web site contains links to other sites such as Youtube and Facebook. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements (such interesting reading and the obvious “go to first” page of any website!) of any other site that collects personally identifiable information.

FINALLY…

I will not sell, distribute or lease your personal information to third parties unless I have your permission or are required by law. You have my word.

MEMBERSHIP SITE PRIVACY INFO

The Tranquil Living Tribe is a membership platform that uses Wild Apricot as the Membership Management Software (MMS). For information about Wild Apricot’s GDPR Policies:

White Papers
https://www.wildapricot.com/gdpr?_ga=2.85749977.179694987.1588861981-1588496958045

Data Processing Agreement
https://www.wildapricot.com/dpa?_ga=2.85749977.179694987.1588861981-1588496958045

The membership site collects the following date which is necessary to fulfill the purpose of your membership:

Full Name
Email
Phone Number
New Client Intake Waiver

You may optionally upload an avatar image to your profile and participate in the group forums where your topic comments and responses will be stored. You may also upload up to two additional images within your profile.

Nature and Purpose of Data Processing:

  • Membership management
  • Event registration
  • Online payments
  • Email and contact database
  • Website builder
  • Mobile solutions

You may change your privacy settings by:

  1. Logging into your account.
  2. Clicking the View profile link.
  3. Click the Privacy link.
  4. Click the Edit profile button to enter edit mode.
  5. The member can now choose who can view their personal information. If a lock icon appears beside a field, an administrator (yours truly) is the only one who can change it for you. Simply email me your request.
  6. Once they are finished changing their privacy settings, the member clicks the Save button.
  7. Please be aware hiding your profile will make any forum posts “anonymous”.

In addition to profile information, the database will also store event registration details and forum posts. You may request the erasure of your personal data at any time, assuming that certain conditions exist, by contacting me with your request:

  • The data are no longer needed for the original purpose(s) for which they were collected, and no new lawful purpose exists.
  • The lawful basis for processing is consent, the data subject has withdrawn such consent, and no other lawful ground exists.
  • The data subject exercises his/her right to object, and the controller has no overriding grounds for continuing the processing.
  • The data have been processed unlawfully.
  • Erasure is required to comply with EU or member state law.If you feel that we are not abiding by this privacy policy, you should contact us immediately via telephone at 1-571-494-1967 in the USA or +33 (0)783611432 in France or via email.

Updated May 8, 2020