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Terms & Privacy Policy

You signed up for Helena's Readers' List emails, news, stories, and relevant promotional details. It's hoped you're finding them interesting! If not, you can leave Helena's Readers' any time with the unsubscribe link I always provide in any communication with you. If you're curious how I use your personal data check out my privacy policy. Read all about it below.

Effective Date: Feb 22nd 2017
Last Updated Date: May 5th 2020

TERMS OF USE

This website: helenatrooperman.ca and helenatrooperman.com which references this .ca website exclusively, adhere’s to the parent site’s Privacy Policy. See this policy replicated below.

Helena Trooperman is a pseudonym of Helen Bartley and Helena Trooperman is a ‘Home Author’ of Hollowbury.

SUPER DUPER IMPORTANT

The parent site for helenatrooperman.ca is: hollowbury.ca which is the main site for Hollowbury, hollowbury.com references the .ca site exclusively.

Hollowbury is an Ontario based, Canadian registered organisation. As such Canadian legislation is adhered to first and foremost. (CASL, PIPEDA)

Hollowbury is not open to approaches made by other client authors at this time.

ALSO IMPORTANT – NOT SUPER DUPER

Helena Trooperman is an author of Speculative Fiction. (Super duper to her, though!)

Whilst Helena does have links to social media, the platforms are kept separate from this website. The links do allow a visiting client to find her social pages in those platforms and connect with her. These interactions are client driven. When a client (a visitor) to this site takes a link to a third party site, the client becomes covered under the third party site’s Terms and Privacy at that point.

PRIVACY POLICY

Thanks for your interest in Hollowbury. Data protection is of a particularly high priority for the management of the Hollowbury Group and its affiliates and authors, collectively Hollowbury. The use of the Internet pages of Hollowbury is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our websites, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with Canadian privacy legislation, specifically Federal Personal Information Protection and Electronic Documents Act (PIPEDA), and Canada’s Anti-Spam Legislation (CASL). Furthermore, Hollowbury aims to meet the expectations of the General Data Protection Regulation (GDPR) to the extent that this is possible whilst operating in Canada. Hollowbury operates in accordance with applicable the country-specific data protection regulations. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, Hollowbury has implemented numerous technical and organizational measures to ensure the protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. DEFINITIONS
The data protection declaration of Hollowbury is a Canadian organization and meets Canadian privacy legislation expectations. While under no obligation to meet Europe’s privacy requirements, this policy is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
A) PERSONAL DATA
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
B) DATA SUBJECT
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
C) PROCESSING
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means or otherwise, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
D) RESTRICTION OF PROCESSING
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
E) PROFILING
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
F) PSEUDONYMISATION
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
G) CONTROLLER OR CONTROLLER RESPONSIBLE FOR THE PROCESSING
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
H) PROCESSOR
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
I) RECIPIENT
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of an inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall follow the applicable data protection rules according to the purposes of the processing.
J) THIRD PARTY
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
K) CONSENT
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. NAME AND ADDRESS OF THE CONTROLLER
Controller for the purposes of Canadian privacy obligations, but also the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Hollowbury,
c/o 126 Davidson Blvd, Dundas, ON, L9H7M5, Canada.
Email: support@hollowbury.com
Website: https://www.hollowbury.com and https://www.hollowbury.ca . Individual authors will have their own websites or page (actually on the hollowbury website), which will adopt this privacy policy as the parent policy.

3. COOKIES
The Internet pages of Hollowbury use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Hollowbury use cookies to provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

4. COLLECTION OF GENERAL DATA AND INFORMATION
The website of Hollowbury collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, Hollowbury does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Hollowbury analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. REGISTRATION ON OUR WEBSITE
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees will be available to the data subject in this respect as contact persons.

6. SUBSCRIPTION TO OUR NEWSLETTERS
On the website of Hollowbury, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
Hollowbury informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if the data subject has a valid e-mail address.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our email newsletter may be terminated by the data subject at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

7. NEWSLETTER-TRACKING
The newsletter of Hollowbury contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Hollowbury may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. Hollowbury automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. CONTACT POSSIBILITY VIA THE WEBSITE
The websites of Hollowbury (including Helena Trooperman) contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for processing or contacting the data subject. There is no transfer of this personal data to third parties.

9. COMMENTS FUNCTION IN THE BLOG ON THE WEBSITE
Hollowbury offers users the possibility to leave individual comments on individual blog contributions on a blog, which is on the website of the controller. A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts. Blogposts may usually be commented by third parties.
If a data subject leaves a comment on the blog published on this website, the comments made by the data subject are also stored and published, as well as information on the date of the commentary and on the user’s (pseudonym) chosen by the data subject. In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged. This storage of the IP address takes place for security reasons, and in case the data subject violates the rights of third parties or posts illegal content through a given comment. The storage of these personal data is, therefore, in the own interest of the data controller, so that he can exculpate in the event of an infringement. This collected personal data will not be passed to third parties, unless such a transfer is required by law or serves the aim of the defense of the data controller.

10. SUBSCRIPTION TO COMMENTS IN THE BLOG ON THE WEBSITE
The comments made in the blog of Hollowbury may be subscribed to by third parties. There is the possibility that a commenter subscribes to the comments following his comments on a blog post.
If a data subject decides to subscribe to the option, the controller will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address decided in favor of this option. The option to subscribe to comments may be terminated at any time.

11. ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

12. RIGHTS OF THE DATA SUBJECT
Hollowbury seeks to comply with all its National and International privacy legislative obligations. Hollowbury asserts how (irrespective of the actual location of the data subject) that it seeks to comply with European GDPR expectations:
A) RIGHT OF CONFIRMATION
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
B) RIGHT OF ACCESS
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
* the purposes of the processing;
* the categories of personal data concerned;
* the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
* where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
* the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
* the existence of the right to lodge a complaint with a supervisory authority;
* where the personal data are not collected from the data subject, any available information as to their source;
* the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
C) RIGHT TO RECTIFICATION
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Considering the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
D) RIGHT TO ERASURE (RIGHT TO BE FORGOTTEN)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, if the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the reasons applies, and a data subject wishes to request the erasure of personal data stored by Hollowbury, he or she may, at any time, contact any employee of the controller. An employee of Hollowbury shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Employees of Hollowbury will arrange the necessary measures in individual cases.
E) RIGHT OF RESTRICTION OF PROCESSING
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Hollowbury, he or she may at any time contact any employee of the controller. The employee of Hollowbury will arrange the restriction of the processing.
F) RIGHT TO DATA PORTABILITY
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may at any time contact any employee of Hollowbury.
G) RIGHT TO OBJECT
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Hollowbury shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If Hollowbury processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Hollowbury to the processing for direct marketing purposes, Hollowbury will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Hollowbury for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of Hollowbury. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
H) AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Hollowbury shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of Hollowbury.
I) RIGHT TO WITHDRAW DATA PROTECTION CONSENT
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of Hollowbury.

13. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF CONVERTKIT
On this website, the controller has integrated ConvertKit services. ConvertKit provides email services for Hollowbury. The services permit users to sign-up to, receive, and manage their email service relationship with Hollowbury.
The operating company is ConvertKit, Idaho, USA.
The purpose of ConvertKit is to allow us to manage emailing services including newsletters and book updates based on settings which users have signed up to.
Further information and the actual data protection provisions of ConvertKit may be retrieved under https://convertkit.com/privacy/ and https://convertkit.com/terms/

14. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF DRAFT2DIGITAL PRESENTED AS BOOKS2READ TO THE USERS’ CLIENTS.
On this website, the controller has integrated Draft2Digital services. Draft2Digital provides book product distribution services for Hollowbury. The services allow users to select the right format of digital media for them and to subsequently procure it from a vendor. Currently no information is passed from Hollowbury to Draft2Digital regarding data subjects however they are listed here since Draft2Digital may subsequently request personal data, for book delivery and distribution.
The operating company is Draft2Digital, 5629 SE 67th Street, Oklahoma City, OK 73135
The purpose of Draft2Digital is to allow us to create particular formats of digital books and permit users to link to vendors so that users may procure selected digital books from specific vendors.
Further information and the actual data protection provisions of Draft2Digital may be retrieved under https://www.draft2digital.com/privacy-policy/

15. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF BOOKFUNNEL
On this website, the controller has integrated Bookfunnel services. Bookfunnel provides book product distribution services for Hollowbury. The services permit users to sign-up to, upload their book or story and provide a download link for it, Helena can use in emails to distribute the product without charge. On following the link, the services allow users(readers) to select the right format of digital media for them and to subsequently procure it from Bookfunnel’s relationship with Hollowbury. Currently no information is passed from Hollowbury to Bookfunnel regarding data subjects however they are listed here since Bookfunnel may subsequently request personal data for book delivery and distribution.
The operating company is Bookfunnel, USA.
The purpose of Bookfunnel is to allow us to create particular formats of digital books and permit users to link to them so that users may procure selected digital books with assistance if they need it.
Further information and the actual data protection provisions of Bookfunnel may be retrieved under https://bookfunnel.com/privacy/ and https://bookfunnel.com/terms/  to contact about privacy at legal@bookfunnel.com.

16. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF KINGSUMO WEBSITE ADD-IN.
On this WordPress website, the controller has integrated KingSumo as an add-in service. KingSumo provides email services for Hollowbury. The services permit users to provide setup and entry to the specified Sweepstakes/Contest for a specified prize(s), and then select the random winner(s) and confirm those entered by email, and the winner by email through KingSumo service relationship with Hollowbury. Entrants are not automatically on the users email list, but are given options to join through the user’s ConvertKit relationship. At the end of the contest when all entrants have been notified of the winner, those that have not opted-in to the ConvertKit mailing list will be notified their details will be deleted within 10 days.
The operating company is KingSumo, USA.
The purpose of KingSumo is to allow us to manage a timed Sweepstakes/Contest services including the collection of name and email addresses and select a random winner(s) for the specified prize(s).
Further information and the actual data protection provisions of KingSumo may be retrieved under https://kingsumo.com/privacy/ and https://kingsumo.com/terms/

17. DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF KDP AFFILIATE PROGRAM. (AN AMAZON COMPANY)
On this website, the controller has integrated KDP Affiliate Program services. KDP Affiliate Program provides tracking for specified product links followed on Hollowbury sites. The services permit users to sign-up to, receive affiliate links to allocate to products on their website, and provide a small payment to the user for the sale of the product if it goes through as a service relationship with Hollowbury.
The operating company is KDP Affiliate Program, USA.
The purpose of KDP Affiliate Program is for Hollowbury to earn commission on sales through the links provided on the program which they have signed up to.
Further information and the actual data protection provisions of KDP Affiliate Program may be retrieved under privacy notice at: https://www.amazon.com/gp/help/customer/display.html?ie=UTF8&nodeId=468496

Also see KDP Affiliates operating agreement with Hollowbury: https://affiliate-program.amazon.com/help/operating/agreement/ref=amb_link_VsoWjwjVPtm8JeS_dR2n2Q_17?pf_rd_p=64ccb4cd-31ba-40e9-92be-94c95d237178

18. LEGAL BASIS FOR THE PROCESSING
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

19. THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

20. PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, provided that it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

21. PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT; REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA
Hollowbury do not directly enter into arrangements which cause personal data to be provided by law (e.g. tax regulations) or from contractual provisions (e.g. information about the contractual partner).

22. EXISTENCE OF AUTOMATED DECISION-MAKING
As a responsible company, we do not use automatic decision-making or profiling.

23. PROTECTION OF CHILDREN
We do not market to children under 13.

24. CLARIFICATION ON WEB SITE SECURITY
We host our website services at Siteground, (www.siteground.com). However, the websites themselves will not hold personally identifiable information since they are used solely for presenting information from and about Hollowbury and its authors.

Blog Postings

The only information from users that could be recorded on the websites is in the form of public comments where pages may be configured to permit public comments from being collected and added.

Hollowbury appreciate all comments and the effort that our readers and participants spend to share their thoughts and give feedback. However, we seek to meet the expectations of all of our readers. While we keep the majority of comments, we will remove these:

* Harassing comments: While conversation and the sharing of different ideas is encouraged, all comments need to be respectful towards our contributors and those leaving comments.
* Inappropriate comments: If comments are of an inappropriate, sexually derogatory or otherwise demeaning nature we will remove them.
* Anonymous comments: We only accept comments from people who identify themselves.
* Promotional comments: If a comment is solely promotional in nature, we will remove it from the site.
We reserve the right to remove any comments from the site; website users should only post comments that are respectful.

If you have any questions on the commenting policy, please contact Hollowbury.

Website Security

Hollowbury procure secure website services from SiteGround. This includes the scanning and rectification of vulnerabilities to all infrastructure, hosts and services in their care, custody and control as well as providing a procured vulnerability scanning service on Hollowbury-owned websites to identify and alert Hollowbury of potential issues which require actions such as patching and reconfiguration. Hollowbury assert that we will respond to all alerts within 12 hours of notification.

For clarity, our web servers only provide articles and information. We will never ask for credit card numbers or sensitive personal information. Where books and other services may be procured, they are handed off to a payment service as necessary. Any payment service selected will be PCI DSS compliant.

We use Malware and threat monitoring systems and scanning on all internal systems.

Any personal information collected is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.

Users enter, submits, or access their information directly via secured ConvertKit services (details provided earlier) to maintain the safety of your personal information.

25. Canadian Anti-Spam Legislation (CASL)

This section of policy is specifically written to address Canadian Anti-Spam Legislation. It is noted that GDPR language and assertions overlap with CASL, however for Canadian residents using Hollowbury services, this section of policy will take precedence.

Specifically, this Policy applies to Hollowbury when:
1. Sending electronic messages from any Hollowbury account or Hollowbury owned domain name for the purpose of promoting, advertising, marketing, or selling a Hollowbury product or service or promoting Hollowbury’s brand(s) (referred to under CASL as “commercial electronic messages” or “CEMs”);
2. Receiving opt-out/unsubscribe directives to unsubscribe an electronic address from receiving future CEMs;
3. Altering the transmission data of electronic messages; or
4. Installing computer programs onto another person’s personal computer system (for example a home computer) during the course of commercial activity. This includes installing
malware or computer programs that the user did not consent to.

Definitions:
Altering transmission data: Manipulating or changing the transmission data (e.g. the electronic address in the ”To:” line of an email message) so that the electronic message is delivered to a destination/recipient that is different than or in addition to that which was indicated to the sender, unbeknownst to and without the sender’s express consent.

CASL Champion: Hollowbury employee designated as its primary contact in its understanding CASL.

Commercial activity: Anything of a commercial nature (e.g. an activity that promotes a product(s), good(s), or service(s) to a person(s) or encourages a person(s) to engage in the purchase of a product(s), good(s), or service(s)), whether or not there is an expectation of profit.

Commercial electronic messages (CEMs): Electronic messages (e.g. text (SMS/MMS), sound, voice or image) sent to an electronic address (e.g. email, instant messaging, telephone account, or any similar account) that, based on the message content, links, or contact information in the message, encourages participation in a “commercial activity”.

Computer program: Data representing instructions or statements that, when executed in a computer system, causes the computer system to perform a function.

Express consent: Permission that.is specifically given by an individual to receive messages, which has been documented in writing.

Implied consent: Consent that can be inferred based on the nature of the service being provided, that the individual is knowingly giving permission.

Social media: Digital technologies and practices that enable people to use, create, and share content in many forms, including text, images, audio, video, and other multimedia communications. Examples include blogs, social networking websites such as Facebook, Twitter and Linkedln, and video sharing websites such as YouTube.

Transmission data: The information about where, how, and when electronic communication is sent (e.g. the sender’s and recipient’s domain/email address/phone number, the date/time the message was sent, etc.).

Third party: A Third Party is an entity or individual that supplies a particular service or commodity to Hollowbury. The terms third party, third party provider, service provider, affinity partner, vendor and supplier and consultant can be used interchangeably.

General Principles:

Sending CEMs
Every person governed by this Policy will be responsible for ensuring they meet prescribed CASL requirements for the sending of CEMs and unsubscribing an electronic address from receiving future CEMs.

All outbound CEMs will:
1. Have the requisite (implied or express) consent from the recipient;
2. Identify that Hollowbury is sending the message;
3. Include requisite Hollowbury contact information; and
4. Provide an easy method for recipients to opt out of receiving CEMs from Hollowbury.

Sending messages via Social Media platforms

Direct messages via social media may only be sent if the direct message is in response to an inquiry or a question. Additionally, only Hollowbury employees who have been specifically authorized to do so may use external Social Media channels to communicate for Hollowbury business purposes.

For clarity – “Direct messages” sent via social media are sent directly to individuals at an electronic address, as opposed to “indirect messages”, which include blog posts on micro blogging and social media sites (that are not posted to an electronic address) such as LinkedIn, Facebook.

Consent

All employees will ensure they have prior implied or express consent to send a CEM to an electronic address.

Messaging Formalities

All CEMs sent by employees will be sent in accordance with this policy.

Obtaining Express Consent to Send CEMs

Express consent must detail the purpose for which the consent is being sought;
The contact information for Hollowbury; and
A statement that consent can be withdrawn at any time.

Documenting and Storing Consent

Electronic proof of consent must be stored for a minimum of three (3) years.

Checking for Unsubscribe

Hollowbury will verify and respect the unsubscribe status of electronic addresses before sending any CEMs.

Honouring Unsubscribe Requests

Unsubscribe requests must be honoured within ten (10) business days of receipt and electronic mail lists must be updated accordingly.

Emails to Foreign Countries

When sending CEMs to recipients outside of Canada, Hollowbury will comply with the requirements of CASL.

Exception Management

Departures from this Policy will be assessed on a per-case basis and details will be documented and retained for audit purposes.