Privacy Policy

Privacy Policy

Evan Kleiman is committed to safeguarding your privacy. Contact us at [email protected] if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.

By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy

Table of Contents

  1. Definitions used in this Policy
  2. Data protection principles we follow
  3. What rights do you have regarding your Personal Data
  4. What Personal Data we gather about you
  5. How we use your Personal Data
  6. Who else has access to your Personal Data
  7. How we secure your data
  8. Information about cookies
  9. Contact information

Definitions

Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – evankleiman.com

Data Protection Principles

We promise to follow the following data protection principles:

  • Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.

  • Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
  • Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
  • Processing is limited with a time period. We will not store your personal data for longer than needed.
  • We will do our best to ensure the accuracy of data.
  • We will do our best to ensure the integrity and confidentiality of data.

Data Subject’s rights

The Data Subject has the following rights:

  1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
  2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
  3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
  4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
  5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
  6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
  7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
  8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
  9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
  10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
  11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.

Data we gather

Information you have provided us with
This would be your e-mail, name, address, company, speaking, class event or consulting info, comments and or phone number – mainly information that is necessary for answering your inquiry or to enhance your customer experience with us via our newsletter. We also save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name, e-mail address and possibly phone number.

Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your IP address. This information is used to improve your customer experience. When you use or look at the contents of our website, your activities may be logged.

Publicly available information
We might gather information about you that is publicly available.

How we use your Personal Data

We use your Personal Data in order to:

  • provide our service to you. This includes, for example, registering your account so you can comment on articles; providing you with information about our services that you have requested; and communicating with you in relation to those products and services; communicating and interacting with you, and notifying you of changes to any services.
  • enhance your customer experience;
  • fulfill an obligation under law or contract;

We use your Personal Data on legitimate grounds and/or with your Consent.

On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:

  • to identify you;
  • to provide you a service or to send/offer you a product;
  • to communicate either for sales or invoicing;

On the ground of legitimate interest, we Process your Personal Data for the following purposes:

  • to administer and analyse our client base (history) in order to improve the quality, variety, and availability of products/ services offered/provided;
  • to communicate with you regarding a project

As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behavior to be our legitimate interest.

With your consent we Process your Personal Data for the following purposes:

  • to send you our newsletter
  • for other purposes we have asked your consent for;

We Process your Personal Data in order to fulfill our obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymize Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymized. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, indefinitely as a matter for tax records. We save your email and name data to communicate with you via newsletter indefinitely too but you can unsubscribe from the newsletter list using the unsubscribe link at the bottom of every newsletter we send you.

We might process your Personal Data for additional purposes that are not mentioned here but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:

  • the link between purposes, context and nature of Personal Data is suitable for further Processing;
  • the further Processing would not harm your interests and
  • there would be appropriate safeguard for Processing.

We will inform you of any further Processing and purposes.

Who else can access your Personal Data

We do not share your Personal Data with anyone other than our company. Personal Data about you is in some cases provided to our trusted partners  in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:

Our processing partners:

Our business partners:

Connected third parties:

We only work with Processing partners who are able to ensure an adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

How we secure your data

We do our best to keep your Personal Data safe.  We use safe protocols for communication and transferring data (such as HTTPS). We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks. We use SSL for secure transmission of data and have DDOS protection for the website.

Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

If you have an account with us, note that you have to keep your username and password secret and use a strong, secure password.

Children

We do not intend to collect or knowingly collect information from children. We do not target children with our services.

Cookies Policy

We use cookies and/or similar technologies to analyze customer behavior, administer the website, track users’ movements, and to collect information about users. This is done in order to personalize and enhance your experience with us.

A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

We use cookies for the following purposes:

Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.

NAMEPURPOSEEXPIRES
__cfduidused to identify individual clients behind a shared IP address and apply security settings on a per-client basis. For example, if the visitor is in a coffee shop where there are a bunch of infected machines, but the specific visitor’s machine is trusted (e.g. because they’ve completed a challenge within your Challenge Passage period), the cookie allows us to identify that client and not challenge them again. It does not correspond to any user ID in your web application and does not store any personally identifiable information.48 hours

Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.

Commentators
If you comment on an article on this website, WordPress uses the following cookies:

NAMEPURPOSEEXPIRES
comment_author_{HASH},comment_author_email_{HASH},
comment_author_url_{HASH}
Your name, email address and website address.2 years from set/update
jetpack_comments_subscribe_{HASH},jetpack_blog_subscribe_{HASH}Remembers the state of the post and comment subscription checkboxes.2 years from set/update

Cookie Policy Advisory
If you visit our site for the first time and have not pressed Accept button a bar appears at the bottom of the page advising you that the site uses cookies and has a link to our cookie policy for more details:

NAMEPURPOSEEXPIRES
viewed_cookie_policyYou have accepted the cookie policy1 year from set/update.

Newsletter Subscription
For displaying the newsletter subscription popup our site uses the following cookies:

NAMEPURPOSEEXPIRES
hwp-{NUM}_hideIndicates if you have or have not clicked on the Accept button.1 day
hwp-{NUM}_shownIndicates if the cookie privacy bar has been shown to you.1 day
hwp_visit
An ID representing your visit.9 months
hwp_newIndicates if you are new to the site.1 day

Analytics cookies – these cookies are used to track the use and performance of our website and services

Google Analytics is a web analytics service provided by Google, Inc. (“Google”), to help us understand how our websites are used. Information about your use of our website, including your IP address, may be transmitted to Google and stored on their servers. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

NAMEPURPOSEEXPIRES
_utmaThis cookie lets us know if you’ve visited before, so we can count how many of our visitors are new to a group or to a certain page.2 years from set/update
_utmbThis works with _utmc to calculate the average length of time you spend on the site.30 minutes from set/update
_utmcThis works with _utmb to calculate when you close your browser.when you close your browser
_utmtUsed to throttle request rate.10 minutes
_utmvUsed to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.2 years from set/update
_utmzThis tells us how you reached our site (e.g. from another website or a search engine).6 months from set/update
_gaTo distinguish users.2 years from set/update
_gatTo throttle request rate.10 minutes from set/update
_gidUsed to distinguish users.24 hours/update

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

Contact Information

If you have any concerns or questions about our privacy policy please contact us at [email protected] or at 310.450.5183.

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy.
Last modification was made on June 23, 2018.