Last updated June 25, 2024
This privacy notice for KMsobercoach ( "we," "us," or "our" ), describes how and why we might collect, store, use, and/or share ( "process" ) your information when you use our services ( "Services" ), such as when you:
- Visit our website
at http://www.kmsobercoach.com , or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at kathy@kmsobercoach.com .
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we collect any information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request , or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
names
phone numbers
email addresses
billing addresses
debit/credit card numbers
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Acuity Scheduling . You may find their privacy notice link(s) here: Effective Date: August 28, 2023 Squarespace (“Squarespace”, “we”, “us” or “our”) respects your privacy. When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights. By using any of Squarespace’s Services, you confirm you have agreed to the Terms of Service and read and understood this Privacy Policy and our Cookie Policy. Certain jurisdictions require us to provide you with specific additional information. Please see this page for such additional information if you are in: (I) California; or (II) Virginia, Colorado, Connecticut or Utah. 1. Some key terms In our Privacy Policy, when we refer to “Users”, we mean our customers who use our Services, including visitors to our sites. We explain who we are in the “Who is Squarespace?” section below. The users, visitors and customers of our Users’ sites are “End Users”. Any other capitalized terms not defined in this Privacy Policy have the meanings in our Terms of Service. 2. How does this Privacy Policy apply? This Privacy Policy describes what we do with personal information that we collect and use for our own purposes (i.e., where we are a controller), such as your account information and information about how you use and interact with our Services, including information you submit to our customer support as well as certain information relating to your End Users, such as, if applicable, End User information provided to the Squarespace Payments Services (as defined in the Squarespace Payments Terms). This Privacy Policy does not apply to personal information of our employees or job applicants (except to the extent employees or job applicants are Users). This Privacy Policy also includes the right to object to certain types of processing we carry out (see Section 7 below to find out more). We use cookies and similar technologies. Our Cookie Policy describes what we do in that regard. With respect to personal information in Squarespace’s possession, we play a few different roles under global data privacy laws. In order to understand your and Squarespace’s obligations, it’s important to understand the difference between Squarespace Controlled PI and User Controlled PI. “Squarespace Controlled PI” means personal information for which Squarespace determines the purposes and means of processing. This Privacy Policy and this additional U.S. state information page only address Squarespace Controlled PI. “User Controlled PI” means personal information for which a User determines the purposes and means of processing. For User Controlled PI, Squarespace acts as a data processor, service provider or similar term under applicable law. User Controlled PI includes User Content and End Users' personal information described in Section 12 that we host and process on behalf of our Users. Our Users tell us what we do with User Controlled PI on our Users’ instructions. Our Users are responsible for ensuring that their collection and processing of User Controlled PI complies with applicable law. If you are a User looking for contractual provisions about how Squarespace will treat and secure your User Controlled PI, please see our Data Processing Addendum. We explain below how we collect and use Squarespace Controlled PI and your rights. If you are an End User of one of our User’s sites and want to know how a User handles your information, you should check the site's privacy policy. 3. Personal information we collect We collect various personal information regarding you or your device. This includes the following: Information you provide to create an Account, specifically email address, first name and last name. Information you provide if you sign up for Paid Services. For most Paid Services, this will include your billing address as well as a portion of your payment information which is provided to us from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card). The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our sites is available to others. If you use the Squarespace Payments Services through the Services, in accordance with the Squarespace Payments Terms, additional information to set up, manage and provide the Squarespace Payments Services and integrate them with the Processor Services (as defined in the Squarespace Payments Terms), including information about you and your business, such as bank account details, name, address, phone number, date of birth, social security number, tax identifier (EIN), photo identification and nationality. Information you share with us in connection with surveys, contests or promotions. Information from your use of the Services or, where you are an End User, from your use of Users’ sites. This includes: IP addresses, preferences, web pages you visited prior to coming to our or our Users’ sites, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our Users’ sites (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors). Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when a partner of ours shows you one of our ads on or via its advertising platform. Other information you submit to us directly or through Third Party Services if you use a Third Party Service to create an Account (based on your privacy settings with such Third Party Service). 4. How we collect personal information We obtain personal information from various sources. We do this in three main ways: You provide some of it directly (such as by registering for an Account). We record some of it automatically when you use our Services or Users’ sites (including with technologies like cookies). We receive some of it from third parties (like when you register for an account using a Third Party Service, when you purchase our products from an authorized reseller or when you make payments to us using our payment processor or via a mobile app store). We’ve described this in more detail below. a. Personal information you provide When you use our Services, we collect information from you in a number of ways. For instance, we ask you to provide your name and email address to register and manage your Account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions. Sometimes we require you to provide us with information for contractual or legal reasons. For example: (i) when you register or transfer a domain name through the Services, in order to comply with ICANN, registry, ccTLD or registrar policies, we collect your domain registration information; (ii) we may ask you to provide a mailing address and/or select your jurisdiction when you sign up for Paid Services to determine if, and how much, tax we need to collect from you; or (iii) if you use the Squarespace Payments Services through the Services, in accordance with the Squarespace Payments Terms, in order to provide the Squarespace Payments Services and to comply with our contractual and legal obligations, we collect additional information related to the Squarespace Payments Services and Processor Services, including information about you and your business, such as bank account details, name, address, phone number, date of birth, social security number, tax identifier (EIN), photo identification and nationality. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it. b. Personal information obtained from your use of our Services When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information in our mobile apps. If you are an End User of our Users’ sites, we also get information about your interactions with their sites, though we use this in anonymous, aggregated or pseudonymized form which does not identify you directly. We use this data to evaluate, provide, protect or improve our Services (including by developing new products and services). Some of this information is collected automatically using cookies and similar technologies when you use our Services and our Users’ sites. We let our Users control what cookies and similar technologies are used through their sites (except those we need to use to properly provide the Services, such as for performance or security related reasons). You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device. c. Personal information obtained from other sources If you use a Third Party Service (such as Google) to register for an Account, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name and email address (we don’t collect or store passwords you use to access Third Party Services). Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service. If you sign up for Paid Services via a Third Party Service acting as an authorized reseller of our products, the authorized reseller may provide us with: (i) account information on your behalf, such as your name and email address; and (ii) information necessary for us to complete your Paid Services sign up, such as your domain registration information. If you sign up for Paid Services directly with us, we obtain limited information about your payment card from our payment processor, such as the last four digits, the country of issuance and the expiration date. Currently, our payment processor is Stripe. Stripe uses and processes your complete payment information in accordance with Stripe’s privacy policy. This paragraph is not applicable if you sign up for Paid Services as an in-app purchase via a mobile app store in which case the mobile app store’s privacy policy will apply. Please see Google's privacy policy and Apple's privacy policy for information about how they use and process your payment information. This paragraph is also not applicable if you sign up for Paid Services via a Third Party Service acting as an authorized reseller of our products. Please see the authorized reseller’s privacy policy for information about how they use and process your payment information. 5. How we use your personal information We use the personal information we obtain about you for the following purposes: Provision of the Services to Users. Create and manage your Account, provide and personalize our Services, register or transfer your domain names, process payments and respond to your inquiries. If you use the Squarespace Payments Services through the Services, in accordance with the Squarespace Payments Terms, to set up, manage and provide the Squarespace Payments Services, integrate them with the Processor Services and to initiate Transactions (as defined in the Squarespace Payments Terms) on your behalf. Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements. Surveys and contests. Administer surveys, contests and other promotions. Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Squarespace and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your subscription plan or what we think may interest you based on other information we hold about you. Advertising. Analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for Paid Services or we may choose to serve you a particular advertisement based on your subscription plan or what we think may interest you based on other information we hold about you. Customizing the Services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose, such as remembering which of Your Sites you most recently edited. Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not identify you directly. For example, if we learn that most Users of Paid Services use a particular integration or feature, we might wish to expand on that integration or feature. Security. Ensure the security and integrity of our Services. If you use the Squarespace Payments Services through the Services, in accordance with the Squarespace Payments Terms, conduct fraud and risk monitoring, verify your identity, determine if you are eligible to use certain Squarespace Payments Services, and investigate fraud, mitigate financial loss or other harm to you, other Users or your or their End Users. Third party relationships. Manage our vendor and partner relationships. Enforcement. Enforce our Terms of Service and other legal terms and policies. Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse). Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts or law enforcement requests. If you use the Squarespace Payments Services through the Services, in accordance with the Squarespace Payments Terms, these legal requirements include know your customer, anti-money laundering or anti-terrorism laws. We process your personal information for the above purposes when: Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time. Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign in to your Squarespace account. Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request. Legitimate interests. We have a legitimate interest in using your personal information, but we won't process your information if your interests, or your fundamental rights and freedoms, override ours. In particular, we have a legitimate interest in the following cases: To operate the Squarespace business and provide you with tailored advertising and communications to develop and promote our business. To analyze and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring Squarespace is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse. To provide and improve the Services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis. To share your personal information with other Squarespace group companies that help us provide and improve the Services. To comply with a court order or binding law enforcement request. To anonymize and subsequently use anonymized information. Protecting you and others. To protect your vital interests, or those of others. Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness or our Users who have a legitimate interest in having their sites function properly and securely and analyzing the usage of their sites so they can understand trends and improve their services. 6. How we share your personal information We share personal information in the following ways: Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide. Users. We share with our Users data regarding usage by End Users of their sites. For example, we provide a User with information about what web page the End User visited before coming to their site and how their End Users interacted with their site. This is so Users can analyze the usage of their sites and improve their services. Payments Services third party service providers. If you use the Squarespace Payments Services through the Services, in accordance with the Squarespace Payments Terms, we may use certain third party service providers (including Stripe, Sift and Plaid) to: (i) operate and provide the Squarespace Payments Services, (ii) provide Processing Services, (iii) perform administrative payment functions, (iv) perform individual identity or bank verification, and (v) prevent or investigate suspected risk, fraud, security threats, illegal and malicious activity or violations of the Squarespace Payments Terms. Domain registration partners. If required to comply with ICANN, registry, ccTLD or registrar policies, we share your domain registration information with such domain registration partners. Business partners. We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing. Third party plugins and social networks. We may share personal information with website plugins, social media platforms or similar Third Party Services to improve your experience, at your direction, or when you intentionally interact with the plug-in. For example, when you use a Third Party Service to create or log in to your Account, we may share your personal information with that Third Party Service. Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage. Process payments. We transmit some of your personal information via an encrypted connection to our payment processor. Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Service) or prevent fraud or abuse of Squarespace or our Users or End Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements. Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third party social media platform on which we advertise to avoid serving Squarespace ads to people who already use Squarespace. Business transfers. If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal or the negotiation of contemplated deals. 7. Your rights and choices Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information. You can access, update, change or delete personal information (or that of your End Users) in your Account. You can also delete your account by following the instructions in this support guide. Please note that we may need to verify your identity in connection with your requests, and such verification process may, if you do not have access to your Account, require you to provide us with additional information we maintain about you to verify your identity. Even if you have access to your Account, we may request additional information if we believe it’s necessary to verify your identity. If we are unable to verify your identity or request, we may not, in accordance with applicable law, be able to fulfill your request. You may also contact us by email at privacy@squarespace.com to submit an access, update, change or deletion request. You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instructions in such communications. Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it. We also will retain personal information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law. You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority: Irish Data Protection Commissioner Data Protection Commission 21 Fitzwilliam Square South, Dublin 2, D02 RD28 Ireland Phone 01 7650100 & 1800437 737 Email: info@dataprotection.ie If you are a resident of the United Kingdom (the “UK”) or otherwise subject to UK data protection laws, you may lodge such complaints with the UK supervisory authority: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF United Kingdom, Phone 0303 123 1113, Live Chat Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal. Our Cookie Policy explains how you can manage cookies and similar technologies. If you are an End User of one of our User’s sites, you should contact them to exercise your rights with respect to any information they hold about you which they control. 8. How we protect your personal information While no service is completely secure, we have a security team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing, of the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities. 9. How we retain your personal information We retain personal information regarding you or your use of the Services for as long as your Account is active or for as long as needed to provide you or our Users with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests. The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread. As Users may have a seasonal site or come back to us after an Account becomes inactive, we don’t immediately delete your personal information when your trial expires or you cancel all Paid Services. Instead, we keep your personal information for a reasonable period of time, so it will be there for you if you come back. You may delete your Account by following the instructions in this support guide and/or contacting us at privacy@squarespace.com and Squarespace will delete the personal information it holds about you (unless we need to retain it for the purposes set out in this Privacy Policy). Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely. 10. Data transfers Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, to our servers in the U.S. We also store personal information locally on the devices you use to access the Services. Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. For example, data we store may be accessible to law enforcement and national security authorities under certain circumstances. We rely upon a number of means to transfer personal information which is subject to: (a) the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR; or (b) applicable UK data privacy laws in accordance therewith. References to GDPR and its provisions include the GDPR as amended and/or incorporated into UK law. These include: Standard data protection clauses. We transfer, in accordance with Article 46 of the GDPR, personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area (“EEA”). We transfer, in accordance with UK law, personal information to recipients that have entered into the UK Information Commissioner’s Office approved international data transfer agreement and the UK addendum to such European Commission approved contract. Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European or UK data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding, enforceable commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules. Data Privacy Frameworks. We transfer personal data to Squarespace, Inc. in the US from, as applicable, the EEA, Switzerland and the UK pursuant to the EU-U.S. Data Privacy Framework, the Swiss-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Frameworks (each individually and jointly, the “Data Privacy Frameworks”). In accordance with Article 45 of the GDPR, an adequacy decision was adopted for the EU-U.S., Swiss-US and UK Extension to the EU-US Data Privacy Frameworks. You can find out more information about these transfer mechanisms here or you can request a copy from us. 11. Data Privacy Frameworks Squarespace, Inc. complies with the Data Privacy Frameworks to provide a legal basis for transfers of personal data to Squarespace, Inc. in the US from, as applicable, the EEA, Switzerland and the UK. Squarespace, Inc. has certified its compliance to the Data Privacy Frameworks. Squarespace, Inc.’s certification extends to its processing of personal information (received from the EEA, UK and Switzerland under the Data Privacy Frameworks) of the type and for the purposes described in this Privacy Policy. This Privacy Policy also describes the types of third parties to which personal information is disclosed (and the purposes for such), individual’s right of access, the choice and means offered to limit the use and disclosure of personal information and that personal information is disclosed in response to legal requests by public authorities where necessary, including to meet national security or law enforcement requirements. Squarespace, Inc. is committed to treating personal information received from the EEA, Switzerland and the UK pursuant to the applicable Data Privacy Framework in accordance with the principles thereof (the “DPF Principles”). You can find our certification here and you can learn more about the Data Privacy Frameworks (as determined based upon the country from which the personal information was received) and DPF Principles by visiting https://www.dataprivacyframework.gov/. Our accountability for personal information we receive and subsequently transfer to a third party is described in the DPF Principles. In particular, we may use third parties to process data on our behalf as described in this Privacy Policy, and we remain liable if they do so in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage. If you have a question or complaint you believe to be within the scope of our Data Privacy Frameworks certification, please contact us first at privacy@squarespace.com, or using the contact details in the “How to contact us” section below. We'll respond within 45 days. For any complaints that we can’t resolve directly, JAMS is the independent organization responsible for reviewing and resolving complaints about our Data Privacy Frameworks compliance. You can contact JAMS free of charge at https://www.jamsadr.com/eu-us-data-privacy-framework. JAMS is an alternative dispute resolution provider based in the US. If your concern still isn't addressed by JAMS, you may be entitled to a binding arbitration under the DPF Principles. For purposes of enforcing compliance with the Data Privacy Frameworks, Squarespace, Inc. is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. Nothing in the Data Privacy Frameworks affects your rights as a data subject to the extent we use any European Commission approved standard data protection clauses for transfers to the US. If there is any conflict between the terms in this Privacy Policy and applicable DPF Principles, the applicable DPF Principles shall govern. 12. End Users’ personal information Our Users who have created a site using Squarespace are responsible for what they do with the personal information they collect, directly or through Squarespace, about their End Users where they are a controller for such processing. This Section 12 is directed to such Users. a. Your relationship with End Users If you’re one of our Users, you will collect personal information about your End Users. For example, during checkout you may ask your End Users to provide their name, address, email address and payment information so that you can complete their orders. You may also use cookies and similar technologies to analyze usage and other trends. You're solely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ information, including personal information you collect about them from us or using Squarespace functionality or cookies or similar technologies. Please be aware that you and Squarespace may be independent controllers of some data (“Independently Controlled Data”). Independently Controlled Data includes data related to your End Users’ interactions with Your Site such as IP address, device/browser details, web pages visited prior to coming to Your Site and browsing activity on Your Site. Independently Controlled Data may be collected by the Services through an End User’s browser and technologies like cookies. Note that Independently Controlled Data is Squarespace Controlled PI with respect to processing by Squarespace (for which we determine the purposes and means of the processing) and User Controlled PI with respect to processing by a User (for which the User determine the purposes and means of the processing). You must publish your own privacy and cookie policies and comply with them. We’re not liable for your relationship with your End Users or how you collect and use personal information about them (even if you collect it from us or using Squarespace functionality or cookies or similar technologies) and we won’t provide you with any legal advice regarding such matters. b. End User payment information If you use the Squarespace Payments Services through the Services, in accordance with the Squarespace Payments Terms, you accept that Squarespace, the Processor providing the Processor Services and certain Squarespace Payments Services third party service providers (such as Sift and Plaid) have the authority to access, use and transmit your End Users’ Transaction, payment (cardholder information) and other information. We share such End Users’ Transaction, payment (cardholder information) and other information with the Processor and certain Squarespace Payments Services third party service providers to provide the Payments Services, to perform administrative payment functions, to perform individual identity or bank verification, to prevent or investigate suspected risk, fraud, security threats, illegal and malicious activity. If you integrate Your Site with a third party eCommerce Payment Processors, Your End Users’ payment information may be processed via third party eCommerce Payment Processors, in accordance with such eCommerce Payment Processors’ terms and policies. We transmit your End Users’ complete payment information when they initially provide or update it only so that we can pass it along to the eCommerce Payment Processors you agree to use. With respect to such third party eCommerce Payment Processors integrated with Your Site, we don’t collect or store your End Users’ payment information. 13. Updates to this Privacy Policy We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification). We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit. This will help ensure you better understand your relationship with us, including the ways we process your personal information. 14. Who is Squarespace? When we say “Squarespace” (or “we”, “us” or “our”), we mean: (a) Squarespace, Inc. if you are a resident of or have your principal place of business in the United States of America or any of its territories or possessions (the “US”); or (b) Squarespace Ireland Limited if you are a resident of or have your principal place of business outside the US. If your place of residence or principal place of business changes, the Squarespace entity that controls your personal information will be determined by your new residence or principal place of business from the date it changes. 15. How to contact us If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at privacy@squarespace.com, or write to us at the addresses below: If you are a resident of or have your principal place of business in the US: Squarespace, Inc. Attention: Legal - Privacy 225 Varick Street, 12th Floor New York, NY 10014 United States If you are a resident of or have your principal place of business anywhere other than the US: Squarespace Ireland Limited Attention: Legal - Privacy Squarespace House Ship Street Great Dublin 8, D08N12C Ireland If you are a resident of or have your principal place of business in the UK, you may prefer to write to Squarespace UK Limited, Attention: Legal - Privacy, 10 John Street, London, WC1N 2EB United Kingdom. .
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To post testimonials. We post testimonials on our Services that may contain personal information.
- To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
- To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us .
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
6. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age .
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at kathy@kmsobercoach.com .
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below .
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at kathy@kmsobercoach.com .
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ( "DNT" ) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized . As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia , you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
Category | Examples | Collected |
A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name |
B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information |
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | ||
Transaction information, purchase history, financial details, and payment information | ||
Fingerprints and voiceprints | ||
Browsing history, search history, online | ||
Device location | ||
Images and audio, video or call recordings created in connection with our business activities | ||
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | ||
Student records and directory information | ||
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | ||
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
Sources of Personal Information
Learn more about the sources of personal information we collect in " WHAT INFORMATION DO WE COLLECT? "
How We Use and Share Personal Information
Learn about how we use your personal information in the section, " HOW DO WE PROCESS YOUR INFORMATION? "
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, " WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? "
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising
(or sharing as defined under California’s privacy law) , the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ( "profiling" )
Depending upon the state where you live, you may also have the following rights:
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including
California's and Delaware's privacy law)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at kathy@kmsobercoach.com , or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at kathy@kmsobercoach.com . We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California "Shine The Light" Law
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 names and addresses of all third parties with which we shared personal information 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 by using the contact details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? "
10. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at kathy@kmsobercoach.com or contact us by post at:
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?