Whitehurst Ventures, LLC
May 21, 2018
Whitehurst Ventures, LLC understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below.
“Our Site” means this website, https://www.makeavisionboard.com.
“The United States and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015.
“We/Us/Our” means Whitehurst Ventures, LLC, a limited company registered in the United States whose registered address is listed in section 15 below.
Information About Us
2.1 Our Site, https://www.makeavisionboard.com, is owned and operated by Whitehurst Ventures, LLC, a sole proprietorship with one owner and zero employees. Our data protection officer and regulator is Susan LaBorde who can be contacted via options shown in section 15 below.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.1 Name (voluntarily submitted by You)
4.2 email address (voluntarily submitted by You)
4.3 IP address (automatically collected)
4.4 web browser type and version (automatically collected)
4.5 web browser type and version (automatically collected)
4.6 operating system (automatically collected)
4.7 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)
5. How Do We Use Your Data?
5.1 We use your data to provide the best possible website experience for you. This includes:
5.1.1 Providing and managing your access to Our Site;
5.1.2 Personalizing and tailoring your experience on Our Site;
5.1.3 Responding to communications from you;
5.1.4 Supplying you with newsletters that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link that is included in every email newsletter;
5.1.5 Market research;
5.1.6 Analyzing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
5.1.7 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
5.2 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.3 Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
5.4 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
6.1 We only keep your personal data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. Our Data Retention Policies are:
6.1.1 We only collect personal data (name and email address) that You voluntarily submit to us in one of three ways:
If You submit a comment on a post or by sending us a message via our contact form, that information is automatically retained in the WordPress database but is not used by us, except that in cases where you submit a question using our contact form, then we may use your email address to send you an answer.
If You submit your name and email address to sign up for a newsletter, we will retain that information until You unsubscribe from the newsletter. Our email list service provider is Mailchimp.
6.1.2 IP addresses, web browser types, operating systems and other information that is collected automatically by Google (Google Analytics) may be kept indefinitely, and your specific information cannot be deleted because none of such data includes any personally identifiable information.
6.2 Some or all of your data may be stored or transferred outside of the United States and/or outside of the European Economic Area. You are deemed to accept and agree to this by using Our Site and submitting information to Us.
6.3 Steps We take to secure and protect your data include:
6.3.1 The only personal information we collect is the name and email address that you choose to submit to us, and we will never share, sell, or rent your personal information to any third party or use your email address for unsolicited mail. Any email sent by Our Company will only be in connection with the provision of agreed services and products.
6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.1 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
9. How Can You Control Your Data?
9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.
9.2 You may also wish to sign up to one or more of the preference services operating in the United States. Such services may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access Our Site without providing any data at all.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). To have your personal data deleted please contact Us using the contact details below in section 15.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority (however, be aware that this is a one person company);
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14. Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorised by law; or
c) You have given your explicit consent.
14.3 Where We use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
14.4 We currently make no automated decisions.
14.5 We currently do not profile your personal data for any purposes.
15. Contacting Us
Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).