Privacy Statement

What you can expect from us in relation to your personal data

INTRODUCTION AND SCOPE OF THIS PRIVACY STATEMENT

Black Rose Limited and Bethany Ward, LLC associated service providers, together “we” or “us”, want to give you the best experience possible. We use the personal information you share with us to make your experience even better. This privacy statement aims to give you a clear view of how we use personal information that you provide, our dedication to protecting it, your rights and the options you have to control your personal information and protect your privacy. It also outlines what personal information we collect about you when you visit our website, how we use your personal information and the third parties we will share it with.

We use personal information for various purposes, as described in detail below.

WHO COLLECTS YOUR PERSONAL INFORMATION

Black Rose Limited and Bethany Ward, LLC controls the processing of any personal information collected through marketing cookies used on the website.  Your interactions on this website are personally controlled through the processing of your personal information when you post or register on our website.

PERSONAL INFORMATION WE COLLECT FROM YOU

“Personal information” is any information that relates to you and identifies you personally, either alone or in combination with other information available to us. We will collect various types of personal information and special categories of personal information about you, including the following (as applicable):

YOUR CLIENT PORTAL 

We will also collect the following information when you sign up for an account if you choose to provide it: your first and last name, and an email address.

USE OF OUR PRODUCTS AND SERVICES

When you use our website we will ask for personal information (at the time of completion we will explain what information is required in order for us to provide the particular product or service, and what information you may choose to provide), such as:

• an address;
• your date of birth and/or confirmation that you are above a certain age;
• your email-address so that we’re able to communicate with you;
• a record of our correspondence with you (including any feedback you have provided), if you have been in contact with us

INFORMATION WE COLLECT AUTOMATICALLY

We will also collect personal information about you when you interact with our brand and website, and how you use them, as follows:

• Websites: we will collect information about the website when you visit and how you use it. A visit to our website results in data being sent from your browser to our servers. We will collect personal information in this way, such as:
  • • your IP address;
  • • the date and time of the visit and how long you remained on our website;
  • • the referral URL (the site from which the visitor has come);
  • • the pages visited on our website; and
  • • information about the device and browser (such as, browser type and version, operating system, etc).
• Cookies and similar devices: We use various technologies to collect and store information when you visit our websites or use our apps, and this will include sending one or more cookies or other similar devices to your device. You will be able to find out how to disable Cookies by accessing the ‘Help’ section of your web browser

SOURCES OF INFORMATION

Most of the information we collect about you will be personal information that you have voluntarily provided to us through our website or by email.

HOW WE USE YOUR PERSONAL INFORMATION

The personal information we collect when you first sign in will be used for identification and authentication purposes across the website so you can use the same account details to log in from any location and on any device. We will create a profile for you with the information needed to provide you with our website services. The personal information we collect from the other sources listed above will be used in the format that it is received, or, where appropriate, will be combined with personal information we obtain from other internal or external sources. We use and analyze this personal information where necessary for the following purposes detailed below:

Improving our brand: we will use your personal information to understand how you use our products and services, to develop more interesting and relevant products and services, to improve our website, as well as to personalize the products and services we offer you. We process your personal information in this way as it is necessary for the purposes of our legitimate interests in providing better products and services for you and other users.

To provide user support: if you contact us (or vice versa), we will use personal information such as your interaction information and contact history to process your request and provide you with the best service possible. We will process your personal information in this way if it is necessary for the performance of a contract with Black Rose Limited or if it is required for us to comply with any legal obligations. If it is not necessary to process your personal data for either of these reasons we will process it as it is necessary for the purposes of our legitimate interests in ensuring we can provide the best service possible.

To engage with you in relation to the programmes or communities you decide to join: we will use your personal information to provide you with the products and services you have requested from us, such as promotions, membership of EverAfter Communities, loyalty programs and events. This will, if applicable, include using your contact details for events. We will process your personal information for the purposes of our legitimate interests in providing these products and services appropriately and ensuring they function correctly. To the extent that we process location data, we do this on the basis of your consent to receiving these services, and we will not process location data before you have provided your consent to us doing so.

Supplemental information you provide to us will be used for the purposes and on the lawful grounds explained in this statement, including to enrich your Everafter profile and to personalize your EverAfter experience.

Marketing: when you sign up to Black Rose Limited/Bethany Ward, LLC create an account, become a Member of our Community, provide feedback or use our website, we will use your personal information to create a profile based on the information we hold about you. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you in one place. We create your profile in accordance with your preferences in order to provide you with the best-personalised experience and newsletters. Below you can find a more detailed description of the ways in which we will use your personal information for these purposes.

What kind of information: the way you interact with our brand across all the different channels described above (e.g. the EverAfter website and social media) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences. This insight gives us the opportunity to offer you the best experience possible. To learn about you and your interests, we analyze your interactions with our brand using various kinds of information, as set out above. If you have given us your consent to send you marketing communications or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us when interacting with us for sending you personalized marketing messages about our products or services and events. In some instances we will also aggregate your personal information with that of other individuals, to create comprehensive reports about how users use our products and services, and experience our brand. This is necessary for the purposes of our legitimate interests in analyzing our brand and determining how to improve our services.

What kind of messages: the messages we will send you will be personalized and tailored to your individual preferences and interests. We use analytics in order to generate such personalized messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us. You also have the option of selecting what content you wish to receive. These messages may contain information about our products and services, events, and news. We personalize these messages on the basis of that it is necessary for the purposes of our legitimate interests in ensuring that we provide the most appropriate information. We will, in certain circumstances, also use the channels for opinion research (such as to ask if you would like to participate in a survey) and to learn about your experience and improve your experience with us, including by sending you personalised messages.

Enrichment of our data: We may combine information you have provided us directly with information collected automatically, such as metadata or IP addresses or where we have collected anonymous browsing data through the use of cookies, we may later determine that this data relates to your browsing history and combine that data with the existing information we hold on you. This is necessary for the purposes of our legitimate interests to ensure that we provide you the most appropriate information and to personalize your experience.

Conducting analytics: we will use the personal information we hold about you (as well as pseudonymized or anonymised information generated from your personal information) to carry out analysis and research. We carry out all such analyses and research on the basis that it is necessary for the purposes of our legitimate interests in understanding our users and ensuring that our products meet the needs of our users. The specific way in which we carry out this analysis is through data science/analytics, whereby we combine information (such as personal information and/or sensitive personal information we have obtained through the use of your browsing history) we hold on a large scale in order to:

•  learn more about our users and their preferences;
•  to identify patterns and trends amongst our users;
•  enhance user experience on our websites;
•  provide information, content and offerings tailored to our users’ needs;
•  for general research and statistical purposes; and
•  for aggregated reporting purposes for Black Rose Limited
•  develop new products and services;
•  monitor performance of our products and services and/or improve our technology;
•  to be able to send you personalized messages
• Analyzing our business: we will use your personal information (including by anonymizing and aggregating it with other users’ personal information) to determine how Black Rose Limited/Bethany Ward, LLC is performing and where improvements can be made. This is necessary for the purposes of our legitimate interests in understanding how our business is performing, and considering how to improve our performance.
• We will ask for your consent if we wish to use your personal information for purposes other than those listed in this privacy statement and as required to do so under applicable law. We will not use your personal information for other purposes before we have received such consent.

HOW WE SHARE YOUR PERSONAL INFORMATION

We treat your personal information with care and confidentiality and do not share it with third parties other than as set out below:

WITH LEGAL AND LAW ENFORCEMENT
Black Rose Limited/Bethany Ward, LCC will disclose personal information where required by law or legal process, for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend EverAfter’s property and legal rights, to protect the personal safety of our website or by order of a valid injunction from a court or law enforcement agency.

WITH YOUR CONSENT
We may share your personal information with other third parties (different from those described above, for example, regulatory bodies) in other limited circumstances. In these instances we will, where required by applicable law, obtain your consent to share your personal information in this way.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We are committed to protecting your personal information and implement appropriate technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction, or damage.

RETAINING YOUR PERSONAL INFORMATION

We will keep your personal information until you request that it is deleted unless a longer or shorter retention period is required by law, is necessary for the course of legal proceedings or is otherwise needed for a particular purpose under applicable law. In such a case, Black Rose Limited will aim to delete your personal information within a maximum period of one month from the date of the request.

INFORMATION ABOUT CHILDREN

As a general rule, we do not intentionally collect personal information about children under the age of 13. If we become aware that we have inadvertently collected personal information about children under the age of 13, we will take steps to delete the information as soon as possible, except where we are required by applicable law to keep it. Where we know a child is above the age of 13, but considered a minor under applicable law, we will obtain parental/guardian consent prior to using that child’s personal information.

LINKS TO OTHER WEBSITES AND SERVICES

Our websites may contain links to third-party websites, and some of our services provide you with access to third-party services (such as social networks and affiliate links). We have no control over how third-party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third-party websites and services or their privacy practices. Please read the privacy statements of any third-party websites or services that you access from our websites or services.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

Fair play and transparency are important to us. We are open about the personal information we collect and have implemented mechanisms to enable you to exercise any rights you might have with respect to your personal information.

WITHDRAWING CONSENT

Where we have obtained your consent in relation to any matter in relation to your personal information (e.g. your consent to receiving informational messages or your consent to the placement of cookies on your device), you can withdraw this consent at any time by contacting us using the contact details set out below or changing your cookie settings.

ACCESS TO, DELETION, AND CORRECTION OF PERSONAL INFORMATION

If you have registered an account with us, you can access your personal information through our website. Our website generally presents you with the option to add, update or remove information we have about you. If any personal information we have about you is not accessible through our website, you can send us a subject access request for access to this information at a cost to acquire your data using the contact details set out at the end of this privacy statement. After receiving your request and sufficient information to verify your identity we will provide you with a copy of the personal information we have about you which you are entitled to have under applicable law. We will also confirm the purposes for which such personal information is being used, its recipients and the origin of the information. You may write to us at any time requesting amendments to certain personal information that you consider to be incorrect or irrelevant or to request that we block, erase or otherwise remove your personal information. You may also write to us at any time to object to our use of your personal information, restrict our use of your personal information, or request that we provide your personal information in a usable electronic format and transmit to a third party (right to data portability). We will comply with these requests in relation to your personal information in line with applicable law.

OPTING OUT AND UNSUBSCRIBING FROM MESSAGES

All our communications contain an easy way to opt-out from receiving future messages, such as a link through which you can unsubscribe or email/ contact page that you may reply to opt-out. If you would like to opt-out of receiving messages you may use the information contained in the messages you have received, or alternatively you could contact us.

Note that if you choose to opt-out of receiving messages in the manner explained above, we will continue to process your personal information, in particular to allow us to understand your interests and preferences, but we will stop using your personal information to send you personalized or non-personalized messages. If you would like us to stop such processing in part or in full, we have explained how to do this in the above paragraph.

CHANGES TO THIS POLICY

We have pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our online privacy statement in order to ensure that it is free of errors and clearly visible on websites, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law. We may update this privacy statement from time to time to keep it up to date, to keep pace with new developments and opportunities relating to the Internet and to stay in line with applicable law. If we make significant changes to this privacy statement, we will inform you by posting a notification on our websites and/or mobile apps along with an updated version of the privacy statement

CONTACT INFORMATION

If you have any questions about our use of your personal information, how to exercise your rights or about our privacy statement you are welcome to contact us or if you prefer to contact us by regular mail, please send us a message via the contact page on the website.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local data protection authority using their website.

LAST UPDATED: 22 May 2018