PRIVACY POLICY
Effective date: February 1, 2022
Cassowaries LLC (“Cassowaries,” “we,” “our,” or “us”) is committed to respecting your privacy and protecting your personal information. This Privacy Policy explains the types of personal information we may collect from visitors to our websites, including ≪jeffwestphal.org≫ and all related websites and web-based services, including for Cassowaries-owned communities (our “Sites”). This Policy also describes how we use personal information, the purpose for sharing and recipients of personal information, and your available rights and choices associated with that information.
This Privacy Policy is provided in a layered format. You can jump to a specific section by clicking on the section below:
- Collection of Personal Information
- Use of Personal Information
- Sharing of Personal Information
- Your Rights and Choices
- Data Security
- International Data Transfers
- Cookie Policy
- Children’s Privacy
- Links to Other Websites
- Changes to This Privacy Policy
- Contact Us
This Privacy Policy does not apply to third-party websites, products or services, even if they link to our Sites. We recommend you review the privacy practices of those third parties before connecting accessing third party websites and sharing any personal information.
We also encourage you to review our Terms of Use to understand how your personal information will be treated as you make full use of our Sites. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.
1. Collection of Personal Information
For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through our Sites will be apparent by the context of the page, and may include but is not limited to the following types of information.
a. Personal information you provide to us
When you communicate with us through our Sites, we may collect your first and last name, email address, phone number, city/state/country, and any personal information that you choose to provide in the content of your message.
b. Information that we automatically collect
Our Sites use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (“Cookies”), which collect information from you automatically as your use our Sites, including:
- Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Sites you are visiting; and
- Usage data, such as geolocation data, browsing history, time spent on the Sites, pages visited, links clicked, language preferences, patterns of use, and the pages that led or referred you to our Site.
We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. For example, some of our community websites may use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues.
Please review our Cookie Policy below for more information about our use of these technologies.
2. Use of Personal Information
a. Our products and services
We use the personal information we collect to provide, maintain and improve our Sites and the services that we offer through them (our “Services”). This includes:
- To provide you with information regarding us and our related products, services and promotions, as well as Jeffrey Westphal and his various entrepreneurial and philanthropic endeavors, related products, and services
- For users to send messages to us or for Jeffrey Westphal and, in his sole discretion, for him to communicate with our users
- To perform analytics for new and existing Services
- To maintain and improve the quality of our Sites and Services
- To protect ourselves, you, and others; prevent fraud; and create and maintain a trusted, secure, and reliable online environment
- To comply with our legal obligations; respond to subpoenas, court orders, or legal process; or to establish or exercise our legal rights or defense against legal claims
b. Digital marketing communications
We may send you promotional email communications about us or Jeffrey Westphal, invite you to participate in events or promotions, or otherwise communicate with you for marketing purposes, as allowed by applicable law. For example, when we collect your contact information through your interaction with our Sites, we may use that information to follow up with you regarding an event or send you information that you have requested about us or Jeffrey Westphal. You may opt out of receiving any, or all, of these communications from us via the unsubscribe link provided in such emails or by following further instructions provided in Your Rights and Choices.
3. Sharing of Personal Information
We may share your personal information with the following categories of third parties:
a. Our affiliates. We may share personal information with our affiliates to provide our Sites and Services and for internal administrative purposes.
b. Service providers. We share personal information with our service providers to provide services on our behalf, such as payment processing, analytics, hosting, marketing, customer and technical support, and other services. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use the information for any other purpose.
c. Compliance and harm prevention. We may share personal information as we believe necessary (i) to comply with applicable law, rules and regulations; (ii) to enforce our contractual rights; (iii) to investigate possible wrongdoing in connection with the Site and Services; (iv) to protect and defend the rights, privacy, safety and property of ourselves, you or others; and (v) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
4. Your Rights and Choices
You may have rights and choices regarding our use and disclosure of your personal information. Unless instructed otherwise, you can exercise these rights and choices using the information in the Contact Us section at the end of this Policy.
a. Opting out of receiving electronic communications from us. If you no longer wish to receive email communications from us, you may opt out via the unsubscribe link included in such emails or by following further instructions provided in Your Rights and Choices. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving emails from us, we may still send you important administrative messages that are required in order to provide you with our Services or for other reasons disclosed in this Policy.
b. Your California privacy rights. We do not disclose personal information to third parties for their own direct marketing purposes. However, California residents have the right to request information regarding such practices under California’s “Shine the Light” law. If you are a California resident and would like to inquire further, please Contact Us.
c. Your Nevada privacy rights. Nevada residents have the right to request to opt out of any “sale” of their personal information under Nevada SB 220. We do not currently sell personal information under Nevada law; however, you may still request to opt out of the future sale of your personal information. If you are a Nevada resident and would like to make such a request, please contact us using the information in the Contact Us section at the end of this Policy, and provide “Nevada Privacy Rights” in the subject line. You must include your full name, email address and postal address in your request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.
5. Data Security
The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse.
6. International Data Transfers
Our Sites are operated exclusively in the United States and intended for users located in the United States. We may transfer, store and use information we collect and maintain about you, including personal information outside of your state, province, country or other governmental jurisdiction. The data protection laws in the jurisdiction in which we process personal information may differ from those of your jurisdiction, and in certain circumstances, your personal information may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions. By using the Sites or providing us with any information, you consent to the transfer and processing of your information, including personal information, in the United States as set forth in this Privacy Policy.
If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, we comply with any applicable laws to provide an adequate level of data protection to the U.S. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use EU Standard Contractual Clauses with data recipients located outside the EEA or the UK as well as other appropriate measures and safeguards.
7. Cookie Policy
When you visit our Sites, we may collect information from you automatically through Cookies. We also rely on partners to provide many features of our Sites using data about your use of the Sites. We use Cookies for the following purposes:
- Necessity. To enable features that are necessary for providing you the services on our Sites, such as keeping you signed in, improving security, and preventing and detecting fraud.
- Preference. To allow us to remember your preferences and identify you when you return to our Sites.
- Analytics. To allow us to understand how our Sites are being used, track site performance and content views, and make improvements to the content, products or services.
- Social Media. To enable the sharing of content from our Sites through social networking and other sites.
You can modify your browser settings to decline or accept Cookies. However, in a few cases, some of our Sites’ features may not function as designed.
We do not support Do Not Track functionality. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
8. Children’s Privacy
The Sites are intended for a general audience and we do not knowingly collect personal information from children under age 18 through the Sites.
If you are a parent or guardian and you are aware that a child under age 13 has provided us with personal information without parental consent, please contact us using the information in the Contact Us section. If we become aware that we have collected personal information from children under age 13 without verification of parental consent, we will take steps to remove that information from our servers.
9. Links to Other Websites
Our Sites may contain links to other websites that are not operated by us. We strongly suggest you review their privacy policies. If any linked website is not owned or controlled by us, we are not responsible for its content or privacy policies, or the practices of the operator of the website or services.
10. Changes to This Privacy Policy
We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws. The “effective date” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Sites. If we make any material changes to this Privacy Policy, we will take reasonable measures to notify you via email and/or a prominent notice on our Platform prior to the change becoming effective, and will update the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.
11. Contact Us
If you have any questions about this Privacy Policy or wish to exercise one of your privacy rights, please contact us by emailing legalnotices@jeffwestphal.org or sending a letter to:
Cassowaries Limited
40 Morris Avenue, Suite 301
Bryn Mawr, Pennsylvania, U.S.A. 19010