Privacy Policy

Privacy Policy

Throughout this Privacy Policy we’ll refer to our websites, mobile applications, and other products, activities, and services collectively as “Services.”

Your privacy is critically important to us. At Family Spirals®, we have a few fundamental principles:

  • We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our Services.
  • We store personal information for only as long as we have a reason to keep it.
  • We aim to make it as simple as possible for you to control what information is shared publicly (or kept private), indexed by search engines, and permanently deleted.
  • We help protect you from overreaching government demands for your personal information.
  • We aim for full transparency on how we gather, use, and share your personal information.

Website Privacy Policy

Our websites are managed by WordPress.com and its parent company Automattic, and its privacy policy.

What This Policy Covers

This Privacy Policy applies to information that Family Spirals® collects about you when you use:

  • Our websites (which are hosted by a third-party, wordpress.com);
  • Our mobile applications (WordPress mobile app for Android and iOS);
  • Our email service, registration and application forms, online meetings (all hosted by Zoho)
  • Payment gateways to pay for services, or to make purchases in our online store (processed by PayPal)
  • Social Media sites

Or when you communicate with us by

  • Making a tax-deductible Donation (processed by Fractured Atlas)
  • Having a conversation (face-to-face, phone, or via apps)
  • Giving us your Business Card

This Privacy Policy also applies to information we collect when you apply for a job, volunteer position (including as an advisor or board member), or internship at Family Spirals®.

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Creative Commons Sharealike License

This Privacy Policy is modified from Automattic’s Privacy Policy, and falls under the same Creative Commons Sharealike license they use. You can grab a copy of their Privacy Policy and other legal documents on GitHub.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.

We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

We operate using different third-party apps, software, and services, and we get information from them. The purpose for using these apps follows, with links to their privacy policies:

Fractured Atlas for donations

PayPal to pay for services, products and events

WordPress.com for subscriptions, comments, and contact forms on our websites

Zoho applications, including Forms for registration and applications to Services, our primary Mail service, and Zoho Meetings

Social Media pages, including: LinkedIn, Facebook, Twitter, Instagram, Pinterest, YouTube.

Information You Provide to Us

We collect information that you provide to us directly. Here are some examples:

  • Basic contact information: We ask for basic information from you in order to keep you abreast of our Services: name and email address. You may provide us with more information — like your physical address and other information you want to share — but we don’t require that information.
  • Public information: We keep information confidential. There are only a few occasions in which some of your information may be seen by others. You decide how much of your information may be made public.
    • In online Services: when you participate in a service or activity we offer, to keep your name private from other participants, you may use a pseudonym. However, for our professional trainings – actual names and organizations represented will be used within services.
    • On social media: if you express interest in our Services on social media, the information in your public profile will be seen by others unless you opt to keep your information confidential. Information in your public profile usually includes your name and photo, and other information you decide to share.
    • Donations: we may list the names of donors and their range of donation in newsletters and/or on our website. When you make a donation, you have the option of keeping your name confidential. Tax-deductible donations are made through a third party, our fiscal sponsor, Fractured Atlas (see their Privacy Policy). We never receive any credit card or bank information; we only receive name, email, amount donated, and date/s of donation.
    • Testimonials/Artwork: If you agree to let us post a portion of your story, or a work of art you created, on our website or in a pamphlet, you determine how much information to share.
    • We collect the information that you provide for your public profile on a WordPress website, other personal or professional website, and social media account. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
  • Payment and contact information: There are various ways in which you may provide us payment information and associated contact information. For example, if you pay for one of our services, or buy something from us, we’ll collect information from our payment gateway software (currently PayPal), including: name, date of transaction, amount in USD, and email. We also keep a record of the purchases you’ve made. For donations. You may also provide the payment gateway with financial details to set up a payment, automate monthly donations, vehicle donations, including PayPal account information or your bank account information. If there is an employer matching gift donation, we’ll also have contact information about your employer. However, we do not store any financial information.
  • Other information: We collect additional information from you in order to keep you abreast of new services, activities, products, information, and campaigns using information you provide us including your name, your contact information, your social media profiles, your employer, your interests, and your communications with us. Information is collected from such items as emails, orders, correspondences, voluntary survey answers, donations, and social media. Please note: survey answers are kept strictly confidential on survey software.
  • Content information: You might provide us with information about you in draft and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
  • Communications with us: You may also provide us with information when you respond to surveys, communicate with us via email with a question or comment, post a question in our public forums, or sign up for a newsletter. When you communicate with us via form, email, phone, WordPress.com comment, or otherwise, we store a copy of our communications.
  • Job applicant information: If you apply for a job, volunteer position, or internship with us — you may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.

Information We Collect Automatically

We also collect some information automatically:

Transactional information: When you make a purchase through our Services, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction. This includes when you purchase something we sell or when you use our Services to buy something from a third party.

Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Automattic uses cookies and other technologies like pixel tags to identify and track visitors, usage, and access preferences, as well as to track and understand email campaign effectiveness and to deliver targeted ads. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see Automattic’s Cookie Policy.

Information We Collect from Other Sources

We may also get information about you from other sources. For example:

Third Party Login: If you create or log in to your WordPress.com account through another service (like Google) we’ll receive associated login information (e.g. a connection token, your username, your email address)

The information we receive depends on which services you use or authorize and what options are available.

Third-party services may also give us information, like mailing addresses for individuals who are not yet our users. We use this information for marketing purposes like postcards and other mailers advertising our Services.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

  • To provide our Services. For example, to set up and maintain your contact information; provide our Services; provide customer support; correspondences; to process applications, orders and donations; satisfaction surveys; other surveys; and announcements.
  • To ensure quality, maintain safety, and improve our Services. For example, by monitoring and analyzing how users interact with our Services, we can create new features and programs that may benefit you and others dealing with family-related issues.
  • To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Family Spirals® and others, which may result in us, for example, declining a transaction or terminating Services.
  • To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
  • To customize the user experience. For example, to personalize your experience by serving you relevant notifications about our Services, ….
  • To communicate with you. For example, by emailing you to ask for your feedback, share new information, or keep you up to date on Family Spirals®; verify your payments and registrations; or to share requested information. If you don’t want to hear from us, you can opt out of communications at any time.
  • To recruit and hire staff, and to recruit volunteers, interns, advisors, partners, board members. For example, by evaluating applicants and communicating with them.

Legal Bases for Collecting and Using Information

A note for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to keep you abreast of our Services — for example, in order to enable access to our website on your device or charge you for a service or activity; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our programs; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or

(5) The use is necessary to visit the content on our websites – for example, our website hosts, Automattic, gives you the option to consent or decline having cookies placed on your device which can be accessed and analyzed later on, as described in their Cookie Policy.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in the section called Ads and Analytics Services Provided by Others:

  • Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
  • Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you. This includes vendors that help us provide our Services to you (like Fractured Atlas for donations, payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you; those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); survey and survey analysis software; other third-party tools that help us manage operations; and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies (e.g., Automattic’s Cookie Policy).
  • Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request. For more information on responses to requests for information about our website users, please see Automattic’s Legal Guidelines.
  • To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Family Spirals®, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
  • Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Family Spirals® goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
  • With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so, like when you authorize/permit us to post a portion of your story or artwork online.
  • Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
  • Published support requests: If you send us a request for assistance (for example, via email or one of our other feedback mechanisms), we will not publish that request.

We have a long-standing policy that we do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.

We may show ads on our websites, and the revenue generated lets us offer free access to some of our Services.

Under a new California law, the California Consumer Privacy Act (“CCPA”), some personalized advertising you see online and on our sites might be considered a “sale” even though we don’t share information that identifies you personally, like your name or email address, as part of our advertising program.

Learn more about Automattic’s ads program here.

Information Shared Publicly

Information that you choose to make public is disclosed publicly.

That means information like your public profile, posts, other content that you make public, and your “Likes” and comments on other websites are all available to others.

For example, for others registered with WordPress.com, the photo that you upload to your public profile, or a default image if you haven’t uploaded one, along with other public profile information, displays alongside the comments and “Likes” and other interactions that you make on our websites while logged in to your WordPress.com account.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.

Security

While no online service is 100% secure, we work hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so.

Choices

You have several choices available when it comes to information about you:

  • Limit the information that you provide: You can choose not to provide the optional profile information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
  • Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
  • Set your browser to reject cookies: At this time, Automattic does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Automattic’s websites, with the drawback that certain features of Automattic’s websites may not function properly without the aid of cookies.
  • Request Separation: While we’d be very sad to see you go, you can request separation from our organization. Please keep in mind that we may continue to retain some of your information, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

  • Request access to your personal data;
  • Request correction or deletion of your personal data;
  • Object to our use and processing of your personal data;
  • Request that we limit our use and processing of your personal data; and
  • Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it.

The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

  • Identifiers (like your name, contact information, and online identifiers);
  • Commercial information (your purchase history, for example);
  • Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
  • Internet or other electronic network activity information (such as your usage of our Services, like the comments you make on our websites);
  • Geolocation data (we only collect physical addresses, but third party sources as our website provider, collects location data based on your IP address);
  • Audio, electronic, visual or similar information (such as your artwork submitted as part of our Services);
  • Professional or employment-related information (for example, information you provide in a job application, or for a matching gift); and
  • Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above. We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section.

If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

  • Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
  • Request deletion of personal information we collect or maintain;
  • Opt out of any sale of personal information (Note: we don’t sell personal information); and
  • Not receive discriminatory treatment for exercising your rights under the CCPA.

You can find detailed metrics about how our website provider, Automattic, complies with these rights in their Privacy Report.

The CCPA & Personalized Advertising in Our Ads Program

We seek to make our Services accessible to as many people as possible. However, we do not sell (or share) information through our ads program that identifies you personally, like your name or contact information. We don’t knowingly sell personal information of those under 18. Learn how you can opt out of our website provider’s use of personal information by going to California: Do Not Sell My Personal Information.

Contacting Us About These Rights

You can access, correct, or delete your personal data by contacting us directly about any of these rights, see “How to Reach Us” below.

When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, we will need you to contact us from the email address associated with your name. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us through our web form or via email.

Other Things You Should Know

Transferring Information

Because Family Spirals® Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, or third-party data processors. This is required for the purposes listed in the How and Why We Use Information section above.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads and Analytics Services Provided by Others

Links appearing on any of our Services may be delivered by advertising or other third party networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver ads or other information that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by Family Spirals® and does not cover the collection of information by any third-party advertisers or analytics providers.

Third-Party Software and Services

If you use the third-party service or grant access, your data will be handled in accordance with the third party’s privacy policy and practices. We don’t own or control these third parties, and they have their own rules about information collection, use, and sharing, which you should review before using the software or services.

Visitors to Our Websites

Automattic process information about visitors to our websites on our behalf and in accordance with our user agreements with Automattic. Please note that processing that information isn’t covered by this Privacy Policy. If you’d like, you can also read more about the data Automattic collects on behalf of its users in their Privacy Notice.

Family Spirals® does control the content posted on our sites, so any disputes regarding that content should be made directly to us, through our web form or via email or by leaving a comment on the site.

Privacy Policy Changes

Although most changes are likely to be minor, Family Spirals®, as well as third-party companies, may change its Privacy Policy from time to time. We encourage visitors to frequently check this page for any changes to our Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (like adding a statement in the Family Spirals® blog or sending you a notification through email). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Translation

Our Privacy Policy was originally written in English (US).

Change Log

10/7/22