What is Personal Data?
Personal Data is information that makes it possible to identify a natural person. This includes in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.
What is Processing?
"Processing" means and covers virtually any handling of data.
What law applies?
Who is responsible for data processing?
The responsible party within the meaning of the PIPEDA and the GDPR is Bootstrapped Woman, a trading name of Real Happy Daughter Inc, (“Bootstrapped Woman”, “we”, “us”, or “our”). If you have any questions about this policy or our data protection practices, please contact us using firstname.lastname@example.org or use our Contact Form.
All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if:
● you have given your consent;
● the data is necessary for the fulfilment of a contract / pre-contractual measures;
● the data is necessary for the fulfilment of a legal obligation; or
● the data is necessary to protect the legitimate interests of our company and business.
We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular Canada's commercial and tax law and others for up to 6 years from the end of the last tax year they relate to). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.
If necessary, we transfer your Personal Data within Bootstrapped Woman. Of course, we comply with the associated legal framework and ensure that your data is processed properly. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to fulfil your order or to contact you in case of queries.
b) External bodies
Personal Data is transferred to our service providers in the following instances:
● in the context of fulfilling your orders, shipping and delivery,
● to use marketing services and to advertise our products online,
● to communicate with you,
● to provide our website and shop, and
● to state authorities and institutions as far as this is required or necessary.
We usually do not transfer Personal Data to countries outside Canada. However, if we do, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.
Security of your data
In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction or access by unauthorised persons, we use appropriate technical and organisational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Your Rights and Privileges
a) Privacy rights
Under the PIPA, you have the following rights:
● Right to be informed
● Right to access
● Right to rectification
● Right to erasure
● Right to object/opt-out
● Right to Consent
● Right to Redressal
Under the GDPR, you can exercise the following rights:
● The right to access;
● The right to rectification;
● The right to erasure;
● The right to restrict processing;
● The right to object to processing;
● The right to data portability;
b) Updating your information
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.
c) Withdrawing your consent
You can withdraw consents you have given at any time by contacting us.
d) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The Office of the Privacy Commissioner, 30 Victoria Street, Gatineau, Quebec, J8X 0A8, www.priv.gc.ca. However, we would appreciate the opportunity to address your concerns before you contact the Privacy Commissioner.
Processing of your Personal Data
a) Log files
When you visit and use our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
c) Cookie consent
Our website uses the cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
We use the hosting services of Hostinger, for the purpose of hosting and displaying our website. Hostinger does so on the basis of processing on our behalf, and that also means that all data collected on our website and shop is processed on Hostinger's servers.The basis for processing is our legitimate interest, and the initiation and/or fulfillment of a contract.
e) Analytical Data
For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. For this purpose we use ConvertKit and Thrivecart. The legal basis is our legitimate interest.
f) Contact options
We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection and the message field itself. In addition, your IP address is processed out of technical necessity and for legal protection. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service and your consent.
g) Meetings and Discovery Call
For the simplified booking of appointments, we use the service of Calendly. By using this service, the data you submit including your Name, Email address and IP Address is transferred to Calendly. The processing of the data entered via Calendly is thus exclusively based on a legitimate interest of simplified appointment arrangement and the initiation of a contract.
h) When using our services
We process the Personal Data involved in your use of our services in order to be able to provide my contractual services. This includes in particular support, correspondence with you, invoicing, fulfillment of my contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.
i) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of my business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing my contractual services. The processing bases are our legal obligations and our legitimate interest.
j) Payment Data
If you make a purchase your payment will be processed via the payment system of Thrivecart and Stripe. Payment data will solely be processed through the payment system of Thrivecart and Stripe. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of email using the services of ConvertKit but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
Promotional use of your data
We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. Doing so we are using the services of ConvertKit
If you have subscribed to our newsletter, we will use your email address and, if applicable, your name to send you information about products, promotions, and news, as well as for customer satisfaction surveys. You will find the unsubscribe link at the end of each newsletter. The legal basis is your consent.
We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.
We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
b) Market research and advertising
c) When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture).
Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. Please take care not to transmit or share sensitive data or confidential information (e.g., application documents, bank or payment data) via social media platforms; we recommend that you use a more secure means of transmission (e.g. e-mail).
Changes and Questions
Wednesday, December 13th 2023.