Updated May 24, 2018
Note: as of May 24, 2018, Smaulgld no longer uses Clicky tracking service as referenced below
Introduction
Smaulgld LLC (we” or “us”) values its visitors’ privacy. This privacy policy summarizes what information we might collect from a registered user or other visitor (“you”), and what we will and will not do with it. This privacy policy is effective March 14, 2014.
Please note that this privacy policy does not govern the collection and use of information by companies that we do not control, nor by individuals not employed or managed by us. If you visit a Web site that we mention or link to, or embed on the site (such as a Youtube or Bitchute video), be sure to review its privacy policy before providing the site with information. Please note that Smaulgld uses as third party site, Disqus for comments. You can can “opt out” of Disqus data collection when you are logged in by clicking here or you can delete your Disqus account entirely by clicking here.
It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to register you as a user. Our policy, however, that allows users to sign up for free email updates using our consent opt in form requires only a valid email address. We use Jetpack for our sign up process. Here is their privacy policy. When you provide your email address via the opt in “subscribe” feature, your email addressed is retained as long as your remain a subscriber to our site. When you unsubscribe, your email addressed is removed from the list.
If you buy a report prepared by us, we will use your personally identifiable information to process the transaction. In such cases, your email address will not be added to our list for free email updates. If you wish to receive free email updates, you will have to opt in separately.
We process transactions (including donations and paid reports) via paypal and coinbase. Here is the paypal privacy policy and the Coinbase privacy policy.
Whenever you donate to Smaulgld LLC or purchase a product from us, we will keep your information indefinitely unless you instruct us to remove it.
“Personally identifiable information” means information that can be used to identify you as an individual, such as, for example:
your name, company, email address, phone number, billing address, and shipping address
your company name user ID and password (if applicable)
any account-preference information you provide us
your computer’s domain name and IP address, indicating
where your computer is located on the Internet
session data for your login session, so that our computer can ‘talk’ to yours while you are logged in
If you do provide personally identifiable information to us, either directly or through a reseller or other business partner, we will:
not sell or rent it to a third party without your permission — although unless you opt out (see below), we may use your contact information to provide you with information we believe you need to know or may find useful, such as (for example) news about our services and products;
take commercially reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction;
not use or disclose the information except:
as necessary to provide services like sending your updates by email;
in other ways described in this privacy policy or to which you have otherwise consented;
in the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);
as required by law, for example, in response to a subpoena or search warrant;
to outside auditors who have agreed to keep the information confidential;
to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or disposition of all or a portion of our assets. The successor organization’s use and disclosure of your personally-identifiable information will continue to be subject to this privacy policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your personally-identifiable information will be subject to the successor organization’s own privacy policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use Smaulgld.com). If you submit personally-identifiable information after such a transfer, that information may be subject to the successor entity’s privacy policy;
as necessary to protect the rights, safety, or property of Smaulgld.com, its users, or others; this may include (for example) exchanging information with other organizations for fraud protection and/or risk reduction.
Other information we collect
We may collect other information that cannot be readily used to identify you, such as (for example) the domain name and IP address of your computer. We may use this information, individually or in the aggregate, for technical administration of our Web site(s); research and development; customer- and account administration.
Cookies
Smaulgld’s advertisers may use “cookies” to store personal data on your computer. If you set up your Web browser (for example, Internet Explorer or Firefox) so that cookies are not allowed, you might not be able to use some or all of the features of our Web site(s).
External data storage sites
We may store your data on servers provided by third party hosting vendors with whom we have contracted.
UIDS
Smaulgld uses a service called “Clicky”, a web analytics provider that tracks Unique ID (UIDs) of our visitor which is lawful without consent as it is well within the “legitimate interests” of a web site to know how many unique visitors are visiting their site. Clicky accomplishes this with a UID tracking cookie that the General Data Protection Regulation (“GDPR”), a law in the European Economic Area (“EEA”), considers be Personal Data, even though it does not identify who a visitor is (e.g. their real name) or reveal anything else about them. ALL IP addresses are anonymized. Please read the Clicky Privacy Policy.
Notice to European Union users
Lawful basis for Collecting Personally identifiable information – Legitimate Interest and Consent
Our operations are located primarily in the United States. If you provide information to us, the information will be transferred out of the European Union (EU) to the United States. By providing personal information to us, you are consenting to its storage and use as described herein.
Legitimate Interest
Through Clicky we have access to UIDs of our visitor which is “necessary for the purposes of our legitimate interests” as defined in the GDPR – i.e. in order to assemble statistics regarding the use of our web site. Using UID and IP personal data is lawful and does not require your direct consent because it is “necessary for the purposes of the legitimate interests” of web sites using the service. These legitimate interests include but are not limited to: assembling statistics regarding the use of a web site; (Accurately counting unique visitors is a vital statistic for any web site). Preventing fraud and abuse, and maintaining information security. (Full IP addresses are necessary for this type of usage). Recital 47 of the GDPR states: “The processing of Personal Data strictly necessary for the purposes of preventing fraud also constitutes a legitimate interest”.
We may also collect personal identifiable information necessary to process transactions or donations.
Consent
We also collect and use email addresses that are freely given to us via our consent opt in form, in order that we may contact our users with content updates. Such content updates will contain links to the Smaulgld.com website which in turn may also contain links to third party websites. If you visit a Web site that we mention or link to, be sure to review its privacy policy before providing the site with information.
Storage of Data
Smaulgld relies on third parties mentioned in this privacy policy to keep your data safe and in accordance with their privacy policies. Smaulgld does not intend to store any of your personal information, other any email addresses that are obtained via direct contact with the Smaulgld @ gmail.com address either due to personal interaction or obtained in connection with a purchase. For example, emails used to sign up for free updates will be stored on Jetpack’s servers in accordance with their policies. Payment information will be stored on Paypal or Coinbase’s servers in accordance with their policies. Analytics data collected will be stored in accordance Clicky’s policies, and cookies will be stored in accordance with affiliate programs or merchants that may be associated with the site from time to time. Smaulgld does not at this time accept or store credit card information.
Smaulgld.com is secured by an SSL certificate and is protected by third party security providers Sucurinet and Wordfence.
Information collected from children
You must be at least 13 years old to use Smaulgld’s Web site(s) and service(s). Smaulgld does not knowingly collect information from children under 13. (See the U.S. Children’s Online Privacy Protection Act.)
Changes to this privacy policy
We reserve the right to change this privacy policy as we deem necessary or appropriate because of legal compliance requirements or changes in our business practices. If you have provided us with an email address, we will endeavor to notify you, by email to that address, of any material change to how we will use personally identifiable information.
Questions or comments?
If you have questions or comments about Smaulgld’s privacy policy, send email to Smaulgld@gmail.com.
Thank you for using Smaulgld.com!
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