ESTHER DE CHARON DE SAINT GERMAIN MY PRIVACY POLICY

Updated April 23, 2018

Your privacy is very important to us. Accordingly, we have developed this policy in order for you to understand how we collect, use, communicate and make use of personal information.

The following outlines our privacy policy. (Seriously I tried to make it as clear as possible!)

1.0 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
•  User privacy and data protection are a human right
•  I have the duty to take good care of all data that is given to me
•   Data is a liability, it should only be collected and processed when absolutely necessary
•  I loathe spam as much as you do!
.  I only work with data that is given to me by the person itself - with consent.
.  I never proces any personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation
• I will never sell, rent or otherwise distribute or make public your personal information
    Scouts honour!

2.0 RELEVANT LEGISLATION
Along with our business and internal computer systems, my three websites (estherdecharon.com, thecreativestudy.com and wonderfullyweird.club) are designed to comply with the following national and international legislation with regards to data protection and user privacy:

UK Data Protection Act 1988 (DPA)
EU Data Protection Directive 1995 (DPD)
EU General Data Protection Regulation 2018 (GDPR)
Australian Privacy Act 1988 (APA)

These sites compliance with the above legislation, all of which are stringent in nature, means that these sites are likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well.

If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.

2.1 DIFFERENT SITES WITH DIFFERENT GOALS
1. estherdecharon.com is intended to inform you about my work and to deliver free value to the public
2. thecreativestudy.com and wonderfullyweird.club are only for paid customers.

3.0 PERSONAL INFORMATION THAT MY WEBSITE COLLECTS AND WHY WE COLLECT IT
This website collects and uses personal information for the following reasons:

3.1 Site visitation tracking on estherdecharon.com
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our sites, to better understand how they find and use our web pages and to see their journey through the website.

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this.

We consider Google to be a third party data processor (see section 6.0 below).

GA makes use of cookies, details of which can be found on Google’s developer guides. FYI our website uses the analytics tracker as the plugin to read GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

In addition to Google Analytics, this website may collect* information (held in the public domain) attributed to the IP address of the computer or device that is being used to access it. 

3.2 Our blog (estherdecharon.com only)
Should you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment.

This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below. Only your name will be shown on the public-facing website although if the supplied email address is linked to a Gravatar account, your Gravatar photo will also be displayed.

Your comment and it’s associated personal data will remain on this site until we see fit to either
1.) remove the comment or
2.) remove the blog post.

Should you wish to have the comment and it’s associated personal data deleted, please email us to office@estherdecharon.com using the email address that you commented with.

If you are under 18 years of age you MUST obtain parental consent before posting a comment on our blog.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.

3.3 Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

3.4 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to Convertkit who provide us with email marketing services. We consider Convertkit to be a third party data processor (see section 6.0 below).

The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.

Your email address will remain within Convertkit database for as long as we continue to use Convertkit's services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the Convertkit database, you will receive periodic (approximately four times a month - or more frequent when something special is happening) newsletter-style emails from us.

Even though I will never give your email to others, you can still receive emails from me about people and services I like you to know about. 

When you are a paying client, you will receive emails about your program or membership. Opting out of these emails is possible but will cause you to miss very important information concerning the service you paid for.

4.0 HOW WE STORE YOUR PERSONAL INFORMATION
As detailed in section 3.2 above, if you submit a comment to a blog post published on the estherdecharon.com website some personal information will be stored within this website’s database.
This is currently the only occasion where personal data will be stored on this website because that is how WordPress works. As soon as it's possible to change that we will change this.

Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on the estherdecharon.com website as soon as we are able to. But not on the membership websites, because it would mean that we cannot support our clients anymore.

4.1 Information stored on thecreativestudy.com and wonderfullyweird.com
These websites are intended only for paying clients. Information about where clients are in the program are only used to support clients. We use third party supplier like Stripe and PayPal .
As soon as you opt-out of a program of membership your personal information will be deleted. Please don't sign up for a membership or coaching programs when you don't want us to track your results.

We don't keep any paper prints with client information.

5.0 ABOUT THE WEBSITE’S SERVER OF ALL THREE WEBSITES
All three websites are hosted by Antagonist  within a Dutch data centre located in the Netherlands.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

6.0 OUR THIRD PARTY DATA PROCESSORS
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All 3 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
•Google (Privacy policy)
•Convertkit (Privacy policy)
for the emails
• Facebook  (Privacy policy)
for the advertisement, Facebook groups and communication
. Instagram (Privacy policy)
for the advertisement and communication
. Yuki (Privacy policy)
for acounting (paying clients only)
. PayPal (Privacy Policy)
. Stripe (Privacy policy)

7.0 DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

8.0 CHANGES TO OUR PRIVACY POLICY
This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

If you have any questions regarding this policy, or your dealings with our website, please contact us here:
Esther de Charon de Saint Germain
decharon coaching & communicatie
office: Borgerderstraat 15
9534PA Westdorp
The Netherlands
esther@estherdecharon.com