PRIVACY POLICY
Effective Date: May 29, 2021
Last Updated: May 29, 2021
This Privacy Policy covers the collection and usage of your personal information by Scott Snibbe Studio (“us,” “our,” “we”) whenever you visit our website, stream or download any file hosted by us, use our apps or installations, or use any of our services in any manner whatsoever (the “Services”). Unless explicitly stated otherwise, your use of any of the Services shall be governed by this Privacy Policy and our Terms and Conditions (“Terms”), where applicable, whether or not you register as a user.
PLEASE FAMILIARIZE YOURSELF WITH OUR PRIVACY PRACTICES AND LET US KNOW IF YOU HAVE ANY QUESTIONS. BY USING THE SERVICES, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
Terms and Conditions
By accessing or using the Services in any manner, you also agree to be bound by our Terms. Please read the Terms carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Terms, please do not use the Services.
Information Collection and Use
We collect information, including Personal Information, to provide better Services to all our users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.
As is standard practice, we also collect non-personally identifiable information which includes, without limitation, IP address, profile information, aggregate user data, device type and browser type, from users of the services. This is described in more detail below.
When you use our Services, we collect Personal Information and non-personally identifiable information in the following ways:
Information You Give to Us
You may choose to provide us with Personal Information about yourself, including your name, address, phone number, and email address, and when you request information about our Services or register for our blog or podcast.
In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Information about yourself when you report a problem or have a question about our Services.
Information We Obtain from Your Use of Our Services
We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account. When you use our Services, we automatically collect and store this information in service logs. This includes: details of how you used our Services; internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. The information we collect automatically is statistical data and may or may not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties.
Location Data: If you grant us access to your location, we may collect information about your location when you use our Services. Your location can be determined by: GPS, IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. If you enable location services for our mobile application, we may collect location data periodically as you use or leave open our mobile application. We may associate such location data with Personal Information you provide to us. Depending on the platform you use to access our mobile application (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the mobile application.
Device ID: When using our Services, we or our service provider may collect your unique device ID. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience. We may associate device ID with personal information you provide to us. You may learn more about opt out of any anonymous device ID collection via the privacy settings available within your mobile device.
Cookies: We use various technologies to collect and store information when you use our Services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with Services from our partners, such as advertising services. Our third-party advertising and analytics partners include Google and similar partners.
The technologies we use for this automatic data collection may include:
Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services.
Web Beacons. Pages of our services or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Services. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Services, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Services.
Mobile Device Identifiers and SDKs. A mobile SDK is the mobile app version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services or analytics to be performed.
Network Advertisers: Third party companies that manage and deliver advertisements to websites and applications are commonly referred to as “network advertisers.” A permitted network advertiser may use cookies, web beacons or similar technologies to collect information about your interaction with the Services or to tailor certain advertisements and content delivered within the Services or on other websites within such network advertiser’s ad network. These companies may also use non-cookie technologies to recognize your computer or device and/or to collect and record information about your web activity including your activities on or off the Services. Please keep in mind that your web browser may not permit you to block the use of these non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques.
Other Advertising: We share certain data with social networks (Facebook, Instagram, etc.) to allow us to target existing users and customers with highly relevant advertising campaigns. We will not share your name, address, email address, telephone number or other personal information for the purpose of such campaigns.
How We Use Information We Collect
We collect and use information for business and commercial purposes in accordance with this Privacy Policy. Our business purposes for collecting and using information include:
– To operate and make available the Services;
– To conduct business to comply with our legal obligations;
– To analyze the use of the Services and for internal market research to improve and grow our business;
– To contact you and deliver (via email, push notifications, or otherwise) product and service updates, special events, special offers, marketing notifications, offers and communications relevant to your use of the Services, with your consent when required under applicable law, as necessary to communicate with you about our Services and promote our business;
– To provide you with customer support in using the Services and to fulfill our contracts with users;
– To enforce the Terms and ensure they are complied with; and
– As otherwise set forth in this Privacy Policy and the Terms.
Legal Basis for Collecting Personal Information
Whenever we collect Personal Information from you, we may do so on the following legal bases:
– Your consent to such collection and use;
– Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
– Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
● Intra-organization transfers for administrative purposes;
● Product development and enhancement, where the processing enables us to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our users, and to better understand how people interact with our Services;
● Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
● Fraud detection and prevention;
● Enhancement of our cybersecurity, including improving the security of our network and information systems; and
● General business operations and diligence.
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
Information We Share
We never sell or rent your contact information to marketers.
In addition, we do not share Personal Information with other companies, organizations, and individuals unless one of the following circumstances applies:
● With Your Consent. We will share Personal Information with companies, organizations, or individuals when we have your consent to do so.
● For External Processing. We provide Personal Information to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. It is our policy to only share Personal Information with contractors, service providers, technology partners, and other third parties who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Services.
● For Legal Reasons. We will share Personal Information with other companies, organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable governmental request; enforce applicable Terms, including investigation of potential violations; detect, prevent, or otherwise address fraud, security or technical issues; or protect against harm to the rights, property or safety of ourselves, our users or the public as required or permitted by law.
We attempt to notify users about legal demands for their Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
● Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Information about our users is often a transferred business asset. In the event that we are acquired by equity acquisition or the purchase of substantially all of our assets, Personal Information about our users may be one of the transferred assets.
● Non-Personal and Aggregate Site Use Information. We may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such De-Identified Information publicly and to third parties. We may also disclose De-Identified Information for general research purposes and in research collaborations with third parties. We may also use De-Identified Information for commercial collaborations with private companies for purposes such as product design or enhancement of Services.
Your Choices and Accessing, Updating or Deleting Your Personal Information
Whenever you use our Services, we aim to provide you with choices about how we use your Personal Information. We also aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.
Your Rights With Respect to Personal Information
Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), corresponding legislation in the United Kingdom, and some U.S. state laws, provide you with certain rights in connection with Personal Information you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
1. The right to be informed. You are entitled to be informed of the use of your Personal Information. This Privacy Policy provides such information to you.
2. The right of access. You have the right to request a copy of your Personal Information which we hold about you.
3. The right of correction: You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
4. The right to be forgotten: You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
5. The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Information, such as the processing of your health information, at any time.
6. The right to data portability: You have the right to a “portable” copy of your Personal Information that you have submitted to us.
7. The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
8. The right to lodge a complaint with a supervisory authority.
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. To make these requests, you may contact us using the contact information below, and we will consider your request in accordance with applicable laws. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Information about you in order to provide our Services or our Services, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
Changing or Deleting Your Information
You may update or correct information about yourself by making changes to your profile by emailing us at privacy [at] snibbe.com. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
We may contact you to request that you update your Personal Information on a regular basis to ensure its integrity for the purposes of ongoing data management.
Our Opt-in/Opt-out Policy
By providing an email address in connection with the Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service related notices, or to provide you with information about our events, invitations, or related educational information.
For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be.
We currently provide the following opt-out opportunities:
1. At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
2. At any time, you can contact us through privacy [at] snibbe.com or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Information.
Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service-related notices.
Third Party Links
The Services may contain links to web pages operated by parties other than us. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the user to take precautions to ensure that whatever links the user selects or software the user downloads (whether from the Services or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the user will be subject to upon linking to the third party’s website. We strongly recommend that each user review the third party’s terms and policies.
Information Retention
We may retain your Personal Information for a period of time consistent with the original purpose for collection. For example, we keep your Personal Information for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
We retain your Personal Information even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.
Security
We maintain administrative, technical and physical safeguards designed to protect the user’s Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we restrict access to personal information to our employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.
Direct Marketing and “Do Not Track” Signals
We do not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. California users may request further information about our compliance with this law by emailing us at privacy [at] snibbe.com.
Changes to this Privacy Policy
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.
How to Contact Us
If you have any specific questions about this Privacy Policy, you can contact us via email or phone or by writing to us at the address below:
Send email to: privacy [at] snibbe.com
Send mail to our address:
Scott Snibbe Studio
Attn: Privacy
4460 Redwood Hwy Suite 16-588
San Rafael, CA 94903
United States