Last update :04/20/2023
Umbrella Journal, Inc (“Umbrella Journal,” “us,” "we," or “our”) is committed to protecting and respecting your privacy in connection with your use of our website, www.umbrellajournal.ca (the “Website(s)”), applications (“Apps”) and other products, services and features thereof (the Website, the Apps and such other products, services and features are collectively referred to herein as the “Product” or “Products”, which may be updated from time-to-time at the sole discretion of Umbrella Journal). This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Products will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data.
We may collect and process the following data about you:
We use information held about you in the following ways:
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at help@umbrellajournal.ca . Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law. Umbrella Journal maintains technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, misuse or disclosure. Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.
If you sign up to receive promotional materials from us via email and/or push notifications we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at help@umbrellajournal.ca, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level. If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply. We will endeavor to comply with these requests as soon as reasonably practicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional email messages from us that are required to provide you with our Products.
Umbrella Journal and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don't have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don't need to do it for every web page requested, and to measure how people are using the Products.
We use local storage, such as HTML5, to store content data and preferences. Third parties with whom we partner to provide certain features on the Products also use HTML5 to collect and store data. Various browsers may offer their own management tools for removing HTML5.
We will acquire consent from you in order to use such trackers or provide you with the opportunity to opt-out of such trackers, to the extent required by applicable law. For more information on the types of cookies used by Umbrella Journal and your ability to restrict the behavior of cookies or disable them in your browser’s settings, please refer to the Umbrella Journal Cookie Policy
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
As true of most websites, we gather certain data and automatically and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
As you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are: A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. We provide an easy-to-view snapshot of such data via the “My Data” tab in the Products.
A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Umbrella Journal will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Umbrella Journal may have legal or legitimate grounds for keeping such data.
A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data. A right to data portability: you have the right to receive the personal data concerning you which you have provided to Umbrella Journal , in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Umbrella Journal . This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Umbrella Journal. Umbrella Journal may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received.
A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Umbrella Journal’s personal data protection practices.
A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Umbrella Journal instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email help@umbrellajournal.ca. You may access your personal data to modify or update at any time via an online account, or by emailing help@umbrellajournal.ca. We will respond to your request in a reasonable timeframe in accordance with applicable law.
In accordance with GDPR, Umbrella Journal provides the following information regarding its Article 6 legal bases for personal data processing: The performance of the contract (the Umbrella Journal Terms & Conditions ) between you and Umbrella Journal for the data processing relating to your use of Umbrella Journals ’s Products (including your orders and payments);
Umbrella Journals’s legitimate interest, more specifically:
We may disclose your personal data with and among our subsidiaries, ultimate holding company, and any affiliates, which include Umbrella Journal CBT Inc.
We may also disclose your personal data to third parties as follows:
The retention periods applied by Umbrella Journal comply with applicable legislation in effect on the date hereof, namely:
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement of a parent or legal guardian under such person's account.
The subsidiaries, service providers or other third parties listed above to whom Umbrella Journal may disclose your personal data may be domiciled abroad, and in particular outside the European Union, Switzerland, and the United Kingdom.
In such case, Umbrella Journal will require them to take, in accordance with applicable legislation, contractual, organizational and technical measures designed to ensure an adequate level of protection of your personal data, such as the use of Standard Contractual Clauses approved by the European Commission.
We remain certified under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield(Privacy sheild).and are committed to the important privacy principles set forth in Privacy Shield. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List,https://www.privacyshield.gov/list
However, in light of the Schrems II decision by the European Court of Justice on July 16, 2020, we are no longer relying exclusively on EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield and are working to implement other transfer mechanisms such as Standard Contractual Clauses to address any transfers of personal data to the U.S., consistent with applicable law.
For personal data collected from individuals located in the European Union, Switzerland and the United Kingdom, you have the ability to opt-out of whether such personal data is disclosed to a third-party (apart from service providers) or is to be used for a purpose that is materially different for the purpose for which it was originally collected or subsequently authorized. You can contact Umbrella Journal at help@umbrellajournal.ca. in order to make such choices.
General disputes arising from your use of our Websites, Apps, Products, and other services can be found in our Terms & conditions .However, if you have any questions or concerns regarding our information collection, use, and sharing practices as described in this Privacy Policy or in this Section 21 regarding Privacy Shield, you may reach us using the contact information at the end of this Policy and we will investigate the matter and resolve any issues, if we can.In the event that we are unable to resolve any such questions or concerns, you may be able to invoke binding arbitration, under certain conditions and as permitted by Privacy Shield, by contacting our U.S.-based third party dispute resolution provider (free of charge) atgo.adr.org/privacyshield.html.Umbrella Journal is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).
Umbrella Journal is mindful of its responsibility and potential liability for onward transfers of personal data to third parties where Umbrella Journal deems such transfers necessary and those transfers are subject to Privacy Shield.
Effective Date: April 20, 2023 Last Reviewed On: May 30, 2023
This California Consumer Privacy Act (“CCPA”) Addendum for California residents supplements the information contained in the above Privacy Policy and applies solely to all visitors, users and others who reside in the State of California. We adopt this CCPA Addendum to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Addendum.
Our Products collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, whether collected online or offline (“personal information”). In particular, the Products have collected the following categories of personal information from consumers within the last twelve (12) months:
CATEGORY | EXAMPLES | COLLECTED |
---|---|---|
Identifiers | First and last name, email address, Internet Protocol address, online identifiers. | No |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | No | |
Internet or other similar network activity. | Browsing history or information on a consumer’s interaction with the Products or our advertisements on third-party platforms. | No |
The specific types of personal information we collect are described more fully in section 1 of the Privacy policy.Personal information does not include: (1) deidentified or aggregated consumer information; (2) publicly available information from government records; or (3) information excluded from the CCPA’s scope.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete when registering for the Products. Indirectly from you. For example, from observing your actions on our Products.
Directly from Partners associated with your Community, if you have a Community Subscription that is authenticated through the Community’s use of eligibility files as described in section 6 of the Privacy Policy
We may use or disclose the personal information we collect for the purposes described in section 9 of the Privacy Policy.
We may disclose your personal information to third parties for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Specific examples of such sharing activities can be found in sections 6 and 11 of the Privacy Policy .
We do not sell your personal information to third parties. We do share a limited set of data that is gathered when you visit our Websites, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements, as further detailed in Section 4 of our Privacy Policy. To the extent this online advertising activity is interpreted as included in California’s broad definition of “data sale”, you may use the opt-out tools described below in Section 5 of this CCPA Notice.
In the last twelve (12) months, we’ve disclosed the following categories of personal information to advertising partners as described above:
Access to Specific Information and Data Portability RightsThe CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will permanently and irrevocably anonymize your personal information, unless an exception applies.
We may deny your deletion request if certain CCPA exemption apply, including but not limited to, if retaining the information is necessary for us or our service provider(s) to:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
Upon receiving a request for access, portability, or deletion, we will confirm receipt of the request within 10 business days and provide information about our verification process and how we will process the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address associated with the account for account holders, and to the email address provided with the request submission for non-account holders.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily readable and useable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Like most companies, we partner with third parties, such as Facebook and Google, to manage our marketing of Umbrella Journal on other platforms, where such advertising is based on your past visits to our Products. These third party partners may use technologies, such as cookies, to gather information about your activities on the Products to deliver such advertising to you when you visit their platforms. For instance, if you visit www.umbrellajournal.ca,a cookie may be attached to your browser in the form of the Facebook Pixel that allows Umbrella Journal to deliver advertising to you on the Facebook platform.
Accordingly, while we do not sell your personal information, if you wish to opt-out of our sharing of the limited data that is gathered when you visit our Websites for purposes of targeted digital advertising, as described in this CCPA Notice and our Privacy Policy, you can opt-out by visiting the Umbrella Journal Cookie Policy and clicking “opt-out of marketing / analytics cookies” at the bottom of the page. Doing so will erase all current marketing cookies and disable the placement of future marketing cookies.
We do NOT use cookies so that third parties can serve ads to you about their own products or services.
We do NOT sell or rent your personal information to any third parties for their own advertising or marketing purposes.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
We reserve the right to amend this CCPA Addendum at our discretion and at any time. When we make changes to this CCPA Addendum, we will post the updated notice on the Website and update the effective date. Your continued use of our Products following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this CCPA Addendum, the ways in which we collect and use your information described above and in the Privacy Policy ,your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to help@umbrellajournal.ca.