Privacy Policy: wildsymphony.com and The Wild Symphony Application

Wildsymphony.com and The Wild Symphony Application are managed and maintained by:
Stellata LLC.
P.O. Box 250
Rye Beach, New Hampshire 03871

We can be reached by email at webmaster@danbrown.com. Please include the words “Privacy Policy” in the subject matter box of your email.

This contact information leads to a limited liability company and does not connect with Dan Brown or persons in his employ. It should not be used to attempt to contact Mr. Brown.

Last updated: March 26, 2020

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.

We use your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Summary

We take your online privacy seriously. You may visit this Website and use the Service anonymously as often as you like without providing any Personal Data. We do not collect Personal Data from you except when you specifically provide it, and we protect the information we receive. If we choose to offer, and you ask to be added to a newsletter or other subscription list, we will use a Cookie to keep track of your requests so that you can easily check and revise any such subscription. We also use Cookies to identify your browser so that we can provide the best link to this Website. When you give us Personal Data for a specific purpose, we will use that information solely for that purpose unless we tell you otherwise and give you an opportunity to OPT IN and then, to OPT OUT, except in rare instances further described below.

The Information You Provide

As you explore this Website, you will come across places in which we ask you to provide us voluntarily with information about yourself. In most of these instances we are seeking only your email address so that we can send you the specific information that you request, such as a newsletter or online subscription or purchase. In other instances, such as a contest, we request both your email address and your name (along with your contest answer), so that we can contact you by name in the event that you win. If you choose to purchase an item that may be offered by us through our direct sales service, we will need to collect additional information for billing and shipping, such as your full name, home address and credit card information. All of these activities–the subscriptions, contests and on-line purchases–are purely voluntary; if you do not wish to reveal your name, email address or other information, you are free simply to ignore these offerings. If you decide to participate, then (subject to the final paragraph of this section) we will not use your name or email address for any purpose other than as stated, and will not sell or rent your name or address to third parties not affiliated with us. If you purchase an item that may be offered at this Website, we may share your credit card information with an independent third party service whose function is to verify the information you provide, and we will store and make available information about recent purchases made through this Website using your password.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for you to access our Service or parts of our Service, if applicable.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application means the software program provided by the Company downloaded by you on any electronic device, named Wild Symphony including, without limitation  the content and functionality thereof.
• CCPA means the California Consumer Privacy Act.  The following are applicable to the CCPA:
  • Business, for the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
  • Consumer, for the purpose of the CCPA , means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the United States for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the United States who is outside the United States for a temporary or transitory purpose.
  • Personal Data, for the purpose of the CCPA, means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you
  • Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.
• Company (referred to as either “the Company”, “we”, “us” or “our” in this Agreement) refers to Stellata LLC.
• Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.
• Country refers to the United States
• Device means any device that can access the Service such as a, computer, smartphone, digital tablet or other mobile device.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• GDPR means the General Data Protection Regulation.  The following are applicable to the GDPR:
  • Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Under the GDPR, you can be referred to as the Data Subject or as the User as you are the individual using the Service.
  • For the purpose of the GDPR, the Company is the Data Controller.
  • For the purposes of the GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
  • For the purpose of the GDPR, Service Providers are considered Data Processors.
• Personal Data is any information that relates to an identified or identifiable individual and as elsewhere described hereunder, as applicable.
• Service refers to the Application or the Website and to each of the Application and the Website individually.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to wildsymphony.com and all content and functionality thereof.
• You or your (including in lower case) means and refers to the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using the Service, there may be opportunities for you to provide (or you may elect to provide) us with certain Personal Data that can be used to contact or identify you. Personal Data may include, but is not limited to:

• Email address which you elect to provide or do provide by contacting us.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies or clear Cookies, you may not be able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as You close your web browser.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To manage requests made by you: To attend and manage communications you might send to us.

We may share your personal information in the following situations:

• With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Service, to help support and maintain our Service, to contact you.
• With Affiliates: We may share your information with our Affiliates, in which case we will require those affiliates to honor this Privacy Policy.

Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of the state, province, country or other governmental jurisdiction of your residence or where you use the Service where the data protection laws may differ than those in such other jurisdictions

Your use of the Service followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Your Personal Data

Business Transactions
If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Governmental Disclosure
Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements
The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data 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 Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Email Marketing

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may use Email Marketing Service Providers to manage and send emails to you.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given your consent for processing Personal Data for one or more specific purposes.
  Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Rights under the GDPR If you are within the European Union

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the European Union to:

• Request access to Your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within the settings section of any account you establish with us, if any.   If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data We hold about you.
• Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of Your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
• Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of Your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if you are a resident of California, you have the following rights:

• The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to access / the right to request. The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
• The right to say no to the sale of Personal Data. The Company has determined that it will not sell your Personal Data to third parties.  However, the CCPA also gives you the right to ask the Company not to sell your Personal Data to third parties.  If the Company were to determine that it might sell Personal Data collected in the future to third parties, the Company would first establish a “Do Not Sell My Personal Information” section or web page for you to request that it not do so in accordance with the CCPA.
• The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
  • The categories of Personal Data collected
  • The sources from which the Personal Data was collected
  • The business or commercial purpose for collecting or selling the Personal Data
  • Categories of third parties with whom We share Personal Data
  • The specific pieces of Personal Data we collected about You
• The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can email us at webmaster@danbrown.com. Please include the words “CCPA Data Protection” in the subject matter box of your email. The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device. The Application does not use location information collected by your mobile device

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children’s Privacy

This Privacy Policy applies to adults and all children who have reached their 13th birthday. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

We also may limit how we collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means we may be unable to provide certain functionality of the Service to these users.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Parents and Guardians

We encourage you to get involved with your children’s online usage and to be aware of the activities in which they are participating. We also ask you to check here regularly to see what our latest policies are, particularly those relating to children.

You should be aware that if your children voluntarily disclose their names, email addresses or other information on bulletin boards or chat areas of websites, such disclosures may result in unsolicited messages from other parties. We suggest that you discourage your child from providing such information on unless you are confident that the information will not be misused.

If you have any concerns regarding privacy issues, please contact us at the above email address.

Parental control protections (such as computer hardware, software, or filtering services) are commercially available and may assist in limiting access to material that is harmful to minors. You can find current providers of such technology by using the following internet search terms: “parental control protections.”

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

Effective Date and Changes in this Privacy Policy

The effective date of this Privacy Policy is March 26, 2020. We will not affirmatively notify users of changes in our Privacy Policy; but we will abide by the Privacy Policy in effect at the time we collect personally identifying information from a visitor, respecting uses of that information.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.