Last updated: May 23, 2018
- ACKNOWLEDGEMENT AND ACCEPTANCE OF TERMS
Slutty Girl Problems, LLC (“Company”) is committed to protecting your privacy. This Privacy Statement sets forth our current privacy practices with regard to the information we collect when you or your computer interact with our website. By accessing www.sluttygirlproblems.com, you acknowledge and fully understand Company’s Privacy Statement and freely consent to the information collection and use practices described in this Website Privacy Statement.
- PARTICIPATING MERCHANT POLICIES
Related services and offerings with links from this website, including vendor sites, have their own privacy statements that can be viewed by clicking on the corresponding links within each respective website. Online merchants and others who participate in Company services are encouraged to participate in industry privacy initiatives and to take a responsible attitude towards consumer privacy. However, since we do not have direct control over the policies or practices of participating merchants and other third parties, we are not responsible for the privacy practices or contents of those sites. We recommend and encourage that you always review the privacy policies of merchants and other third parties before you provide any personal information or complete any transaction with such parties.
- INFORMATION WE COLLECT AND HOW WE USE IT
Company collects certain information from and about its users three ways: directly from our web server logs, cookies, the user, including in response to giveaways, to register as a member of our website, subscribe to our newsletter, leave a comment (only available to members), and content voluntarily shared in forum or comment areas of the site.
a. Web Server Logs.
When you visit our website, we may track information to administer the site and analyze its usage. Examples of information we may track include:
- Your Internet protocol address.
- The kind of browser or computer you use.
- Number of links you click within the site.
- State or country from which you accessed the site.
- Date and time of your visit.
- Name of your Internet service provider.
- Web page you linked to our site from.
- Pages you viewed on the site.
One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. Hence, this simplifies the process of delivering relevant content and eases site navigation by providing and saving your preferences and login information as well as providing personalized functionality.
Company reserves the right to share aggregated site statistics with partner companies, but does not allow other companies to place cookies on our website unless there is a temporary, overriding customer value (such as merging into brenebrown.com a site that relies on third-party cookies).
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you reject cookies by changing your browser settings, then be aware that this may disable some of the functionality on our website.
c. Personal Information of Users
Visitors to our website may be permitted to register for certain services such as a weekly email. When you register, we will request some personal information such as name, address, email, telephone number or facsimile number, account number and other relevant information. We may also collect your information when you submit an email to the website, such as for the purpose or inquiring about the site or submit content to the site.
We will not disclose personally identifiable information we collect from you to third parties without your permission except to the extent necessary including:
- To fulfill your service requests for products or services.
- To protect ourselves, our customer or our vendors from liability or to defend our rights, including investigations of fraud or misconduct.
- To third parties who have agreed in writing to maintain such information in confidence and use such information solely in performance of services to us.
- To respond to legal process or comply with law, including subpoenas.
- To entities under common ownership or control with us or to our owners, or
- In connection with a merger, acquisition, or liquidation of the company.
In any of these cases, we would provide information only to the extent that the situation demands.
Non-identifying personal content submitted, such as age, experiences, questions and testimonials, may be used at our discretion once submitted, as per the Terms and Conditions. Any names, information, details, or likenesses may be changed at any time to keep submitting parties anonymous.
d. Information in Public Areas
You should be aware that if you voluntarily disclose personal information online in a publicly accessible part of the website, that information could be collected and used by others. We do not control the actions of our visitors and registered users. If you disclose personal information in a comment, review, forum, on your profile page, or any other publicly accessible place on this website, you do so at your own risk and you should understand that your information may be collected and used by others to send you unsolicited messages or advertisements, or for other purposes. Please be selective in the kinds of information you choose to disclose in e-mails, exchanges, messages, and comments on public areas of the site and throughout the internet.
How do I withdraw my consent?
If after you opt-in or after having not initially taken an opportunity to opt-out, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at [email protected].
- USE OF WEB BEACONS OR GIF FILES
Company web pages may contain electronic images known as web beacons – sometimes also called single-pixel gifs – that allow Company to count users who have visited those pages and to deliver co-branded services. Company may include Web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon.
Some of these web beacons may be placed by third party service providers to help determine the effectiveness of our advertising campaigns or email communications. These web beacons may be used by these service providers to place a persistent cookie on your computer. This allows the service provider to recognize your computer each time you visit certain pages or emails and compile anonymous information in relation to those page views, which in turn enables us and our service providers to learn which advertisements and emails bring you to our website and how you use the site. Company prohibits web beacons from being used to collect or access your personal information.
- ACCESSING WEB ACCOUNT INFORMATION
We will provide you with the means to ensure that personally identifiable information in your web account file is correct and current. You may review this information by contacting us by sending an email to our support attendant – [email protected].
- DO NOT TRACK
We have not implemented any technology that would effectively recognize do-not-track signals and note that some content available on our Site is made available through relationships with third party providers who we do not control and who may have collect and/or disclose personally identifiable information.
- HOW TO CORRECT, UPDATE, OR DELETE YOUR INFORMATION
If you would like to: access, correct, amend or delete any personally identifiable information we store about you, register a complaint, or simply want more information, contact us at [email protected].
- HOW WE PROTECT INFORMATION
We use commercially reasonable procedures to protect the personal information that we collect from you against loss, theft and misuse, as well as unauthorized access, disclosure, alteration and destruction. We have developed and implemented and continue to maintain and monitor a written information security program applicable to all records containing personal information. This security program is appropriate to the size, scope and type of our business, the resources available to us, the amount of stored data, and the need for security and confidentiality of the personal information we store. No security system is impenetrable. We cannot guarantee the security of our databases or the security during transmission to us of the information you supply over the Internet. You can help us by taking precautions to protect your personal information when you are on the Internet and only disclose information that you want made public. Change your passwords often using a combination of letters and numbers and make sure to use a secure web browser.
- AGGREGATE DATA
We may share and publicize aggregate and/or de-identified information shared with third parties and the public.
- CHILDREN UNDER 16
We do not specifically market to or knowingly collect personal information from children under 16 for marketing purposes. Because some information is collected online, it may not appear to be the personal information of a child under 16. If a child under 16 submits personal information to us and we learn that the personal information is the information of a child under 16, we will attempt to delete the information as soon as possible. If you are under 16, please do not register for any of our services or provide us any information about yourself (such as your name, email address or phone number).
- CALIFORNIA ONLINE PRIVACY PROTECTION ACT
- CHANGES TO THIS STATEMENT
Company has the discretion to occasionally update this privacy statement. When we do, we will also revise the “updated” date at the top of this Privacy page. We encourage you to periodically review this privacy statement to stay informed about how we are helping to protect the personal information we collect. Your continued use of the service constitutes your agreement to this privacy statement and any updates.
14. Information About Cookies
Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Site or using our Services, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Site or Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Services, how often you return, how your use of the Services may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Services. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because we collect browsing and persistent identifier data, the Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave our properties.
Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Site or Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies.
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site or Services. Disabling these Cookies may make certain features and services unavailable.
- Functionality Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Third Party Advertising”.
You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Services and functionalities may not work.
To explore what Cookie setting are available to you, look in the “preferences” or “options” section of your browser’s menu. To find our more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.
15. EU Personal Data
If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined in the EU Privacy Notice below.
EU Privacy Notice
If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
- First and last name
- Email address
- Date of birth
- Biographical information
- Location information (limited to city, state, zip code, country, and time zone)
- Employment history
- Links to your social media accounts
- Any other information you choose to share publicly on the Services, for example, anything you post to a public part of your Profile or an online classroom on the Services
Information we receive from third party sources: Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following:
- Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
- Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
- Information from third party service providers: Some of our third party service providers (such as Lever) collect Personal Data about our employees and job candidates and share that information with us.
Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:
- IP address
- Your activity on the Services. This includes class usage information such as class enrollment and which classes you’ve watched. It also includes community interaction data, such as which members you’re following, your comments, your projects, or project likes.
- Device identifiers
- Web browser information
- Page view statistics
- Browsing history
- Transaction information (e.g. transaction amount, date and time such transaction occurred)
- Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.). For more information, please review the “Information About Cookies” section above.
- Location information (e.g. IP address)
- Log data (e.g. access times, hardware and software information)
How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
- Create and manage user accounts and profiles
- Personalize content on the Services. This includes showing users their saved classes and class watch history, and providing class recommendations.
- Provide users and Teachers with community features
- Provide Teachers with student lists and pay Teachers appropriately
- Communicate with you about the Services
- Contact you with announcements, updates or offers regarding the Services
- Process orders
- Provide support and assistance for the Services
- Analyze and improve the Services
- Meet contract or legal obligations
- Respond and fulfill user inquiries and requests
- Resolve disputes
- Protect against or deter fraudulent, illegal or harmful actions
- Enforce our Terms of Service
- Complete corporate transactions (for more information, see our “Business Transfers” section above)
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
- Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
- First and last name
- Email address
- If you are a Teacher, the content of your classes
- Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- First and last name
- Email address
- Location information
- IP address
- Your activity on the Services, including class usage information and community interaction data
Examples of these legitimate interests include:
- Operation and improvement of our business, products and services
- Personalization of web content on the Service
- Analyzing the use of the Services
- Marketing of our products and services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with legal obligations
- Completion of corporate transactions
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
- Payment processors
- Fraud prevention service providers
- Ad networks and marketing tools
- Analytics service providers
- Engineering and development tools
- Staff augmentation and contract personnel
- Hosting service providers
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services), such as when users and Teachers interact through the Services
- Social media services (if you interact with them through your use of the Services)
- Third party business partners who you access through the Services
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
- Maintain the security of our products and services
We also share information with third parties when you give us consent to do so. Furthermore, you acknowledge that we may transfer your Personal Data, and that any acquirer of us or our assets may continue to use your Personal Data, as set forth in the “Business Transfers” section above.
How Long Do We Retain Your Personal Data? We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.
Personal Data of Children: As noted above, we do not knowingly collect or solicit Personal Data from anyone under the age of 16.
What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing [email protected].
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by making changes to your Profile. You can request that we correct or supplement such data by emailing [email protected].
- Erasure: You can request that we erase some or all of your Personal Data from our systems by emailing [email protected].
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Slutty Girl Problems’ practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data: The Services are hosted and operated in the United States (“U.S.”) through Slutty Girl Problems and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Slutty Girl Problems in the U.S. and will be hosted on U.S. servers, and you authorize Slutty Girl Problems to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.
Slutty Girl Problems is committed to the Principles of the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Slutty Girl Problems compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the Privacy Shield Program, please visit https://www.privacyshield.gov/.
Please contact us at [email protected] with any questions or concerns relating to the Privacy Shield. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.
16. CONTACTING US
If you have questions regarding our Privacy Statement, its implementation, failure to adhere to this Privacy Statement and/or our general practices, please contact us at [email protected]. Company will use commercially reasonable efforts to promptly respond and resolve any problem or question.