The personal information you provide us with is used for delivery of the Freeman e-letters you have opted in to receive (e.g. your name, address, and/or e-mail address). To help fund the cost of publishing the Freeman e-letters, aside from the editorial content you will receive in the Freeman e-letters, you will also receive advertisements for Freeman Publications paid content via e-mail and ad blurbs in our Freeman e-letters. If you want to opt out from receiving these advertisements, or from receiving our Freeman e-letters, you can do so by: (1) using the opt-out link that is at the bottom of our editorial and advertisements e-mails; (2) by contacting us at the mailing address below; or (3) by sending us an e-mail to the e-mail address below.
Examples of ways in which we may collect such information from you include the following:
1.1 We collect general types of information about you when you visit and use our web site; examples include personal information, demographic information, behavioral information, and indirect information. Sometimes we collect combinations of these types of information.
1.2 “Personal information” is information that can be used to identify you or any other individual to whom the information may relate. This is information you are prompted to provide to us. Such information may include your name, address, telephone number(s), mobile numbers, IP address and e-mail address, credit card number(s), bank account(s), or other unique information about yourself that you provide to us during the registration process or though the course of communicating with us about the products and services provided on our web site. We may collect this same information about any other person when you provide it to us.
1.3 “Demographic information” is information that may or may not be unique to you in the sense that it refers to selected population characteristics. Such information may include, but is not limited to, zip code, mobile phone carrier, age, gender, salary range, education and marital status, occupation, industry of employment, and personal and online interests.
1.4 “Behavioral information” is information that is automatically collected pertaining to how you use our web site, the areas of our web site that you visit, what services you access, and information about your computer hardware and software, including your Internet protocol (IP) address, geographic location, browser preference, operating system type, domain names, times that you access the Internet, and other web sites you have visited.
1.5 “Third-party information” is information about you that we acquire from a third party that may include personal, demographic, behavioral, and indirect information. This collection may include, but is not limited to, first-party cookies, third-party cookies, anonymous cookies, persistent identifiers, e-mail opt-in, and search engine keywords. We have no access or control over these cookies and other tracking devices used by third-party advertisers and networks. We hold no responsibility or liability for the policies and practices of these parties.
1.7 No Information Collected from Children: We will never knowingly collect any personal information from children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be immediately deleted from the database. Because we do not collect such information, we have no such information to use or to disclose to third parties.
1.8 No Sensitive Health Information Is Collected: We do not collect information about past, present or potential future medical conditions or treatments.
1.9 Credit Card Information and Bank Account Information: We may, in certain instances, collect credit card number(s), bank account information, and related information when you place an order on our web site. The credit card credentials will be stored for future use. The card will be charged at the rate and frequency agreed to in the initial order, and the credit card credentials will be stored and utilized until you cancel. When the credit card or bank account information is submitted to us, such information is encrypted and is protected with SSL encryption software. We will use the credit card information or bank account information for the purposes of processing and completing the transaction you requested. Such information will be disclosed to third parties as necessary to complete the requested purchase transaction.
Browser information: Browser information is used by us to analyze user trends, administer our web sites, help prevent fraudulent activity, and help collect demographic information. This tracking information may be shared with our affiliated companies, but only as collective information. Individual activity will not be shared externally unless we are required to do so by law, or to protect Freeman e-letters, our other customers, or anyone else who may be at risk.
2.2 Web Beacons: We use electronic images known as web beacons (sometimes called single-pixel gifs, clear gifs, or action tags) that allow us to collect information about your visit to our web site, measure and improve the effectiveness of advertisements, and track delivery of advertising. Web beacons collect only a limited set of information, including a cookie number, time, and date of page view, as well as a description of the page on which the web beacon resides. We may also use web beacons in e-mail messages sent to you. This allows us to determine if you opened or acted upon the e-mail messages. Because web beacons are the same as any other content request, you cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in your browser.
2.4 Mobile Analytics: As part of our analytics, the Freeman e-letters uses software that enables us to get a better understanding of how our sites look and work on mobile devices. Mobile analytics software tracks information on how you interact with our sites on your mobile device. The mobile tracking information we collect may be shared with our affiliated companies, but only collectively. Information on your individual visits will not be shared externally unless we are required to do so by law, or to protect the Freeman e-letters, our other customers, or anyone else who may be at risk.
4.1 We use your personal information to fulfill a contract with you and provide you with our services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good. This includes:
a) To provide payment processing and account management; operate, measure and improve our services; keep our services safe, secure and operational; and customize site content that includes items and services that you may like in response to actions that you take.
b) To contact you regarding your account, to troubleshoot problems with your account or order, to resolve a dispute, to collect fees or monies owed, or as otherwise necessary to provide you with customer service.
c) When contacting you for such purposes as outlined above, we may contact you via e-mail, telephone, SMS/text messages, postal mail, and/or mobile push notifications.
d) To provide other services requested by you as described when we collect the information.
e) We use general location information to provide you with location-based services (such as advertising and other personalized content).
f) To prevent, detect, mitigate, and investigate fraud, security breaches, or other potentially prohibited or illegal activities.
4.2 We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes:
a) Contacting you via e-mail or postal mail in order to offer you coupons, discounts, and special promotions; poll your opinions through surveys or questionnaires; and inform you about our services, as authorized by applicable law.
b) Delivering targeted marketing, service updates, and promotional offers based on your communication preferences.
c) Measuring the performance of our e-mail marketing campaigns (e.g. by analyzing open and click rates).
d) Monitoring and improving the information security of our site.
4.3 With your consent, we may use your personal information to:
a) Provide you with marketing via telephone calls, e-mail, SMS, or text.
b) Provide you with marketing from third parties.
c) Customize third-party advertising you might see on third-party web sites.
5.2 We may disclose necessary personal information to third parties or service providers that help us provide services to you or deliver paid products to you. For example, we will disclose your billing information to payment processors for the purpose of processing transactions you execute with us. Also, we will disclose your shipping address to fulfillment and shipping contractors to deliver your order.
We may also provide your name, customer history, and mailing address to third parties—such as service providers, contractors, and third-party publishers and advertisers—for a variety of purposes, unless you choose to opt out by mailing firstname.lastname@example.org, stating that you wish to be removed from third-party direct mailing offers, along with your name and mailing address.
(b) Web site functionality: We share your information with companies and individuals we employ to perform technical functions on our behalf. Examples include third parties who host our web site, analyze our data, provide marketing assistance, process credit card payments, and provide customer service.
(c) Anonymous information: We share aggregated anonymous information about you, combined with other persons using our web site, with third parties, so that they can understand the kinds of visitors that come to our web site and how those visitors use our web site. This includes demographic information and behavioral information.
(d) Legal process: We disclose your information if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to (a) conform to legal requirements or comply with legal process; (b) protect our rights, property, or affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
(e) Acquisition or merger: We may disclose and transfer your information to a third party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of such information in a transaction approved by the court.
We will honor any statutory right you might have to access, modify, or erase your personal information. To request access and to find out whether any fees may apply, if permitted by applicable national laws, please contact us using the information below. Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws.
Upon your request, we will remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable national laws.
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, contractual agreements, warranties, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your e-mail address is connected to how long your e-mail is subscribed to our mailing list.
Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
10.2. As stated in this Policy, you have agreed to allow us to share information with third parties for their direct marketing purposes until you remove your information, and thus you have agreed to this disclosure. California customers may request further information about our compliance with this law by sending us an e-mail at email@example.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.
a. If you are a customer in the United States (including its possessions and territories), you and we agree that any dispute, claim, or controversy arising out of or relating in any way to the use of our site or sale of our products, these Terms and Conditions of Use, and this Arbitration Agreement, shall be determined by binding arbitration or in small claims court. Arbitration is more informal than a lawsuit in court. Arbitration uses a neutral arbitrator instead of a judge or jury, allows for more limited discovery than in court, and is subject to very limited review by courts. Arbitrators can award the same damages and relief that a court can award. You agree that, by agreeing to these Terms of Service, the U.S. Federal Arbitration Act governs the interpretation and enforcement of this provision, and that you and we are each waiving the right to a trial by jury or to participate in a class action. This arbitration provision shall survive termination of this Agreement and the termination of your account with us.
b. If you elect to seek arbitration or file a small claim court action, you must first send us, by certified mail, a written Notice of your claim (“Notice”). The Notice to us must be addressed to: Freeman Publications, 3300 Hwy 7, Suite 808, Concord, ON L4K 4M3 Canada (“Notice Address”). If we initiate arbitration, we will send a written Notice to the e-mail address used for your membership account. A Notice, whether sent by you or us, must (a) describe the nature and basis of the claim or dispute, and (b) set forth the specific relief sought (“Demand”). If we and you do not reach an agreement to resolve the claim within 30 days after the Notice is received, you or we may commence an arbitration proceeding or file a claim in small claims court.
c. The arbitration will be governed by the Commercial Arbitration Rules and the Supplementary Procedures for Consumer Related Disputes (collectively, “AAA Rules”) of the American Arbitration Association (AAA), as modified by this Agreement, and will be administered by the AAA. The AAA Rules and Forms are available online at www.adr.org, by calling the AAA at 1-800-778-7879, or by writing to the Notice Address. The arbitrator is bound by the terms of this Agreement. All issues are for the arbitrator to decide, including issues relating to the scope and enforceability of this arbitration agreement. Unless we and you agree otherwise, any arbitration hearings will take place in the county of your residence.
d. YOU AND WE AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. Further, unless both you and we agree otherwise, the arbitrator may not consolidate more than one person’s claims with your claims, and may not otherwise preside over any form of a representative or class proceeding. If this specific provision is found to be unenforceable, then the entirety of this arbitration provision shall be null and void. The arbitrator may award declaratory or injunctive relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party’s individual claim.
In addition, you consent to receiving electronic communications from Lombardi Publishing relating to your account. You agree that any notices, agreements, disclosures, or other communications that we send to you electronically will satisfy any legal communication requirements, including that such communications be in writing. You should maintain copies of electronic communications by printing a paper copy or saving an electronic copy. You also consent to receiving certain other communications from us, such as newsletter special offers, promotional announcements, and customer surveys via e-mail or other methods. By placing an order with us, you will be deemed to have read, understood, and agreed to these Terms and Conditions of Use (collectively, “Terms”). If you do not agree to be bound by these Terms, you may not access or use the web site or purchase any products through the web site. By accessing, using, or ordering products through the web site, you affirm that you have read this Agreement and understand, agree, and consent to all Terms contained herein.
We may, from time to time in e-mails, alerts or other communications you have agreed to accept from us, include advertisements, sponsorships, and other offers from, or information about third parties. This does not and will not mean that Freeman e-letters endorses any specific products or services available from such third parties. Such materials from those third parties, regardless of their relationship with us, are provided merely for information purposes and users should make their own judgments and evaluation of any services or products available on any other web sites.
To contact us, or to opt out from receiving our information:
Freeman Publications Limited,
71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM
Freeman Publications Limited,
Attention: Legal – Privacy
71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM
17.2 You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority:
Irish Data Protection Commissioner
Office of the Data Protection Commissioner
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland
Phone +353 57 868 4757
Fax: +353 57 868 4757