Last Updated May 2018
COMMITMENT TO PRIVACY
Your privacy is very important to Start With Small (the “COMPANY”). COMPANY is committed to protecting your privacy. We use the information we collect about you to process orders and personalize your experience at and any other domains that the COMPANY may use (the “SITE”).
Part of the operation of this site involves the collection and use of information about you.
This privacy notice provides you with details of how we collect and process your personal data through your use of our SITE, including any information you may provide through our site when you purchase a product or service, subscribe to our newsletter or request a free resource. This privacy notice may change from time to time, so please check it often.
By using this SITE, you give your express consent to the COMPANY’s privacy notice.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
COMPANY is in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), COMPANY doesn’t collect any information from anyone under 13 years of age. SITE, products, and services are all directed to people who are 13 years of age and older.
By providing us with your data, you warrant to us that you are at least 13 years of age.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We value your privacy and have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We will not distribute your personal information to outside parties without your consent.
TYPES OF DATA COLLECTED
In general, you can visit this SITE without identifying who you are, or revealing any information about yourself.
Information collected online is categorized as anonymous or personally identifiable. COMPANY collects information when you purchase a product or service, subscribe to our newsletter, or request a free resource.
Anonymous data is information that cannot be connected to the identity of a specific individual.
Personal data is information that specifically identifies a particular user, such as but not limited to:
Identity data may include your first name, last name, and gender.
Contact data may include your billing address, delivery address, email address and telephone numbers.
Financial data may include your bank account and payment card details.
Transaction data may include details about payments between us and other details of purchases made by you.
Technical data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Profile data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
Marketing and Communications data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
An example of anonymous data: this SITE may record the number of visits to a particular page that occur in a given period of time, but it does not necessarily tell the COMPANY the names or other identifying information of every visitor. Many users of this SITE choose not to provide any personally identifiable information; therefore, those individuals are anonymous to the COMPANY, and any data collected about their use of this SITE is anonymous information.
When you place an order, request a service, or otherwise voluntarily ask COMPANY to send a good and or service to you, you will voluntarily need to provide the COMPANY with, but not limited to, your name, e-mail address, billing address, shipping, address, and or payment information. This personal data allows COMPANY to process and fulfill your order and to notify you of your order status.
We do not collect any Sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
HOW THE COMPANY COLLECTS YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by email or otherwise, including when you:
order our products or services
create an account on our site
subscribe to our service or publications
request resources or marketing be sent to you
give us feedback
Automated technologies or interactions: As you use our SITE, we may automatically collect technical data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive technical data about you if you visit other websites that use our cookies.
Third parties or publicly available sources: We may receive personal data about you from various third parties and analytics providers such as Google
COMPANY’S USE OF PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
To process transactions
To personalize your experience. Your information helps us to better respond to your individual needs.
To improve our website. We continually strive to improve our website offerings based on the information and feedback we receive from you.
To improve customer service. Your information helps us to more effectively respond to your customer service requests and support needs.
To administer a contest, promotion, survey, or other SITE feature.
To send periodic emails.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at christine [at] startwithsmall [dot] com.
COMPANY collects personal data only for providing the services you voluntarily request, generating statistical studies, conducting marketing research, improving products and services, sending you surveys, or notifying you of new products and any other changes to the SITE and or services that may affect you.
When you voluntarily submit personal data to the COMPANY, you understand that you are agreeing to allow COMPANY to access, store, and or use that information for those purposes.
The COMPANY will not sell or give any personal data to any third parties. Your information whether public or private will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
The COMPANY may be required by law enforcement and or judicial authorities to provide personal data to the appropriate governmental authorities. If requested by law enforcement or judicial authorities, the COMPANY will provide this information on its receipt of the appropriate legal documentation.
COMPANY’s PURPOSES FOR PROCESSING YOUR PERSONAL DATA
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at christine [at] startwithsmall [dot] com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing
To register you as a new customer
Performance of a contract with you to process and deliver your order including:
(a) Manage payments,fees and charges
(b) Collect and recover money owed to us
(e) Marketing and
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(a) Necessary for our legitimate interests for running our business, provision of administration and IT
services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise
(b) Necessary to comply with a legal obligation to deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
(e) Marketing and
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests to develop our products/services and grow our business
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at christine [at] startwithsmall [dot] com.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
TRANSFER OF CUSTOMER INFORMATION
Customer lists and information are properly considered assets of a business. Accordingly, if we merge with another entity or if we sell our assets to another entity, our customer lists and information, including personally identifiable information you have provided us, would be included among the assets that would be transferred.
Prior to such a transfer of assets, you will be provided the opportunity to opt-out or unsubscribe from the customer list.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at info [at] jennyshih [dot] com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
PROTECTION OF YOUR DATA
We operate secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the personally identifiable information provided by our users.
We do not, however, guarantee that unauthorized, inadvertent disclosure will never occur.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers’ database only to be accessible by those authorized with special access rights to such systems. All information is required to be kept confidential.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
COMPANY only uses information supplied via online order and or registration forms voluntarily provided by you.
COMPANY does not sell or rent customer lists.
COMPANY has contracted with a third-party providers, WIX, MailChimp, and PayPal for site hosting, to host email list databases, and process payment respectively. WIX, MailChimp, PayPal have promised that they will not share COMPANY customer information with third parties.
COMPANY uses Google® Analytics to track overall statistics about computer usage on our site. This information is not linked to individual customer information.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
If at any time you do not wish to receive offers, correspondence, and or e-mails from the COMPANY, you may opt-out at any time by clicking the UNSUBSCRIBE link located in the footer of our email correspondence and any time or by emailing christine [at] startwithsmall [dot] com. We include detailed unsubscribe instructions at the bottom of each email.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent
If you wish to exercise any of the rights set out above, please email us at info [at] jennyshih [dot] com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Cookies are small data files, typically made up of a string of text and numbers, that assign the device you are using to access the SITE a unique identifier. This information enables your computer to have a “dialogue” with COMPANY’S SITE and permits the COMPANY to administer the SITE more efficiently; and to provide a more tailored and user-friendly service to you. Cookies can also be used to analyze traffic and for advertising and marketing purposes. Cookies are used by nearly all websites and do not harm your system.
You may set your browser to notify you when you receive a cookie or to prevent cookies from being sent; if you do so, this may limit the functionality we can provide you when you visit our site.
Cookies are either:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. (We use persistent cookies for Google Analytics)
Cookies can also be categorized as follows:
Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.
This SITE contains links to other websites that may offer products or services that our customers might find useful. These sites may request information from you. In such instances, the collection and use of your personal information will be governed by the privacy notice applicable to that site. We do not control the privacy notices, contents or links that appear on these sites. We encourage you to review the privacy notices of any third party sites or services before providing any of them with your personal data.
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of COMPANY’S SITE.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO). We would appreciate if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at christine [at] startwithsmall [dot] com.
If you have any questions regarding this privacy notice, you may contact COMPANY using the information below:
Start With Small
P.O. Box 884
Burlington Ontario Canada L7R 3Y8
christine [at] startwithsmall [dot] com