How We Use and Manage Your Data
COUNTERPLAN.com is run by COUNTERPLAN LLC (“COUNTERPLAN”) respects your right to privacy. We put in place security measures for your personal data and manage your personal data in accordance with applicable data privacy regulations.
Please note that COUNTERPLAN is the Data Controller of your personal data. The principles set out in this Privacy Notice apply to all instances in which COUNTERPLAN receives your personal data as a Data Controller for the purposes described in this notice. Those purposes are processing of data to participate in the various activities available on this website or as mentioned below.
We asked ourselves several key questions that we believe you would like answered about the personal data that you submit to COUNTERPLAN. These answers will, to the extent required by applicable law, inform you of your rights relating to your personal data, the security measures that COUNTERPLAN puts in place regarding your personal data and the uses to which such personal data is put. We trust you find this information helpful.
If you have any requests concerning your personal data or any queries with regard to these practices, please contact COUNTERPLAN using the contact details given in Paragraph 5 below.
- Personal data COUNTERPLAN collects through this website and how COUNTERPLAN collects it?
You can provide your personal data if you wish. We only collect personal data that YOU want to provide to us or that is needed to provide (and improve) our service to you. We collect personal data directly such as name and e-mail address as well as connection and system information. The legal basis for the processing of your personal data is your consent and/or any other applicable legal basis, such as our legitimate interest in engaging in commerce and offering products and services of value to you. Any consent you provide may be withdrawn at any time by following the contact methods listed in Paragraph 5.
- COUNTERPLAN Security Measures
COUNTERPLAN takes security measures in line with data protection regulations. COUNTERPLAN has security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only authorized COUNTERPLAN employees, and authorized employees of our Third-Party service providers’ processing data on our behalf, have access to your personal data. All COUNTERPLAN employees who have access to your personal data are required to adhere to the COUNTERPLAN Privacy Notice and all third-party service providers are requested by COUNTERPLAN to ensure that any of their employees who have access to your personal data have signed non-disclosure agreements. In addition, contracts are in place with such third-party service providers acting as data processors for COUNTERPLAN that have access to your personal data, to ensure that the level of security required in your jurisdiction is in place, and that your personal data is processed only as instructed by COUNTERPLAN.
- How COUNTERPLAN uses your personal data
Your personal data will only be used for the purposes for which you provided it to COUNTERPLAN, as indicated to you at the time you provided your personal data. It will also be used to administer, support and obtain feedback on the level of our services, to help prevent breaches of security, the law or our contract terms, and for direct marketing purposes. It may also be disclosed, including a disclosure to entities based outside the European Economic Area (“EEA”), to third parties (as part of the information generally contained in business) in the event of a sale of the business, or a reorganisation of the business, or as otherwise required or permitted by law or applicable regulator.
- Who COUNTERPLAN discloses your personal data to and why
COUNTERPLAN will never share your personal data with any Third-Party (i.e., a party other than an entity within COUNTERPLAN) business organisation that intends to use it for their own purposes, other than as required by law. COUNTERPLAN, as part of a worldwide group, may transfer or disclose your personal data to another data controller in the COUNTERPLAN Group to be used for similar purposes, at its discretion, and you hereby consent to such transfer or disclosure. If your personal data is transferred or disclosed to another data controller within the COUNTERPLAN Group, that other data controller shall have the same rights and obligations about your personal data as COUNTERPLAN.
With your consent, COUNTERPLAN may share your personal data with Third-Parties (i.e. parties other than entities within the COUNTERPLAN Group) such as those who assist us in providing the products and services and who perform technical operations, but only in the strictly limited circumstances set out below:
Our “Third-Party Data Processors” (service providers such as our fulfilment and activation partners, and digital agencies, hosting providers, data storage providers and other technical partners) who help us administer this website, or process the data submitted to it, may have access to your data. Some of these business partners may be located outside the country where you accessed this website.
- Your rights
You have the right to ask COUNTERPLAN to provide you with all the information it stores on you. If you wish to access your personal data and have an account with COUNTERPLAN, you can click on “My Account” where you will have the opportunity to update your personal data or preferences. You have the right to ask COUNTERPLAN to rectify, block, complete and delete your personal data, to restrict its use, and to port your data to another organization. You have the right to request additional information about the handling of your personal data. You also have the right to object to the processing of your data by COUNTERPLAN in some circumstances and, where we have asked for consent to process your data, to withdraw this consent. Additionally, you may contact our Data Protection Officer at Discovery@COUNTERPLAN.com if you would like assistance with any of the above-mentioned rights.
There are exceptions to these rights, however. For example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if COUNTERPLAN is legally prevented from disclosing such information. In addition, COUNTERPLAN may be able to retain data even if you withdraw your consent, where COUNTERPLAN can demonstrate that it has a legal requirement to process your data.
- Countries your personal data will be sent to and why
COUNTERPLAN is a global company and your personal data may be transferred across international borders.
It may be transferred to countries that have different levels of data protection laws to the country from where you submitted your personal data. COUNTERPLAN (as Data Controller and Data Exporter) has, where local data protection regulations so require, put in place security measures for the export of personal data from its jurisdiction. Where local data protection regulations so require, COUNTERPLAN has made arrangements with entities receiving your personal data such as COUNTERPLAN partners or Third-Party Data Processors, that they shall ensure that security measures are in place, and that your personal data is processed only in accordance with EU Data Protection laws.
If data is transferred from within the EEA to a jurisdiction outside the EEA, it is done so under a Data Transfer Agreement, which contain standard data protection contract clauses. The European Commission has adopted standard data protection contract clauses (known as the Model Clauses) which provide safeguards for personal information that is transferred outside of Europe. We use Model Clauses when transferring personal data outside of Europe. If you wish to know more about international transfers of your personal data, you may contact our Data Protection Officer at Discovery@COUNTERPLAN.com
The server that makes this website available may be located outside the country from which you have accessed this website. The provider of this website is bound by a contract that ensures your data is managed in accordance with EU Data Protection laws and that it acts only on COUNTERPLAN instructions and implements all technical measures necessary on an ongoing basis to keep your personal data secure.
- How and why COUNTERPLAN uses ‘Cookies’ and other similar technologies
This type of information obtained through cookies will not be disclosed outside COUNTERPLAN Group or our authorized Third-Party Data Processors. It will not be used for unsolicited communications.
Cookies located on your computer do not contain your name but an IP address. In many case, after the user's session is cancelled the information contained in the cookies is no longer available to COUNTERPLAN.
Please ensure that your computer setting reflects whether you are happy to accept cookies or not. You can set your browser to warn you before accepting cookies, or you can simply set it to refuse them, although you may not have access to all the features of the website if you do so. See your browser "Help" button for how you can do this. Some Flash Cookies may not be affected by such settings. You do not need to have cookies on to use or navigate through many parts of this and other COUNTERPLAN websites. Remember that if you use different computers in different locations you will need to ensure that each browser is adjusted to suit your cookie preferences.
For further information about Cookies including how to refuse them, please visit www.allaboutcookies.org
- Website customisation
With your consent, and as set out below, we may use the data you give us about yourself when you register online to build up a picture of your interests – so we may then try to ensure that when you visit the site, you don't miss the offers and information relevant to you.
COUNTERPLAN and its reputable third party advertising companies acting on its behalf will collect website usage information about visitors to our website for the purposes of statistical analysis, sales and marketing research, tracking page usage and paths used by visitors through our site, targeting the site content, targeting our marketing campaigns and direct marketing emails, targeting our Internet banner advertisements on our website and on other websites and tracking use of our Internet banner advertisements and other links from our marketing partners' websites to our website.
We may also combine this web usage data with other information we have collected about you, for example, whether you have arrived at our site through a marketing email sent to an individual account, data about your user registration (if you have logged in), and web usage data stored against a previous cookie set on your machine. We store this information so that we have a better and more specific understanding of the way customers are using our site and their preferences and interests. We may use it to undertake sales and marketing research and to tailor our site, our marketing campaigns and email communications specifically to you.
- COUNTERPLAN's policy on collecting data from children
We do not collect personal data from children under the age of 16.
- Retention of your personal data
COUNTERPLAN will retain your information only for as long as is necessary for the purposes set out in this policy. COUNTERPLAN will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, and enforce our agreements. We also retain log files for internal analysis purposes. These log files are generally retained for a short period of time, except where they are used for website security, to improve website functionality, or we are legally obligated to retain them for longer time periods.
- How to contact COUNTERPLAN
The data controller responsible for your personal information for the purposes of the applicable European Union data protection law is:
Data Protection Officer,
4777 SE Graham Drive
Stuart, FL, USA 34997
If you have any questions about this Privacy Notice or our data collection practices, please contact us at the address or email listed above and specify your country of residence and the nature of your question.
Smush sends images to the WPMU DEV servers to optimize them for web use. This includes the transfer of EXIF data. The EXIF data will either be stripped or returned as it is. It is not stored on the WPMU DEV servers.
Smush uses a third-party email service (Drip) to send informational emails to the site administrator. The administrator's email address is sent to Drip and a cookie is set by the service. Only administrator information is collected by Drip.