Privacy

Privacy Policy for ashley.how

(N.B. “I”, “me”, and “mine”, are used to refer to Ashley Howard - the freelance web designer & developer, and site owner.

The privacy of your data — and it is your data, not mine! — is a big deal to me. In this policy, I lay out: what data I collect and why; how your data is handled; and your rights to your data. I promise I will never sell your data: never have, never will.

This policy applies to all products created and maintained by Ashley Howard.

What I collect and why

My guiding principle is to collect only what I need. Here’s what that means in practice:

Identity & access

When you fill out a form on this website, I typically ask for identifying information such as your name, email address, telephone number (optional), and company name (optional). I’ll never sell your personal info to third parties, and I won’t use your name or company in marketing statements without your permission either.

Billing information

When you pay for a product or service, you can either pay directly (via a bank transfer), or through a trusted and secure service (such as Paypal). Your credit card is passed directly to the payment processor or bank and never goes through my servers. I store a record of the payment transaction, and as-of billing address, for account history, invoicing, and billing support. I store your billing address to calculate any sales tax due in the United States or VAT in the EU (if any), to detect fraudulent credit card transactions, and to print on your invoices.

Geolocation data

I log full IP address so that I can always verify no unauthorized access or dangerous activies have occured on this domain. I keep this data for as long as I need to, in order to keep my website safe from spam or attacks.

I also log full IP addresses when using forms on this domain. I keep this record forever because they are used to mitigate spammy signups.

Web analytics data — described further in the Website Interactions section — are also tied temporarily to IP addresses to assist with troubleshooting cases. I blind all web analytics data after 30 days.

Website interactions

Google Analytics

When you browse particular pages on this domain, your browser automatically shares certain information such as which operating system and browser version you are using. I track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. I sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address, and I blind all of these individual identifiers after 30 days. For further details, please take a look at Google’s privacy policy.

Hotjar

I use Hotjar in order to better understand my users ‘needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand my users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain my service with user feedback. Hotjar uses cookies and other technologies to collect data on my users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display my website. Hotjar stores this information on my behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on my behalf. For further details, please take a look at Hotjar’s support page.

Cookies and Do Not Track

I do use persistent first-party cookies to store certain preferences, make it easier for you to use my applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.

At this time, my sites and applications do not respond to Do Not Track beacons sent by browser plugins.

Voluntary correspondence

When you write to me with a question or ask for help, I keep that correspondence, including the email address, so that I have a history of past correspondences to reference if you reach out in the future.

I also store any information you volunteer like surveys. Sometimes when I do customer interviews, I may ask for your permission to record the conversation for future reference or use. I only do so if you give your express consent.

Information I do not collect

I don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when contacting me.

When I access or share your information

My default practice is to not access your information. The only times I’ll ever access or share your info are:

• To provide products or services you’ve requested. I do use some third-party services to run my applications and only to the extent necessary process some or all of your personal information via these third parties. Having subprocessors means I am using technology to access your data. My third-party processors can be viewed here.
• To help you troubleshoot or squash a software bug, with your permission. If at any point I need to access your account to help you with a Support case, I will ask for your consent before proceeding.
• To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. I have an obligation to protect the privacy and safety of both my customers and the people reporting issues to me. I do my best to balance those responsibilities throughout the process. If I do discover you are using my products for a restricted purpose, I will report the incident to the appropriate authorities.
• When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring I share data, I have to comply. Otherwise, I flat-out reject requests from local and federal law enforcement when they seek data. And unless I am legally prevented from it, I’ll always inform you when such requests are made. I have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.

If I am acquired by or merged with another company — I don’t plan on that, but if it happens — I’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.

Location of Site and Data

My products and other web properties are operated in the United Kingdom. If you are located in the European Union or elsewhere outside of the United Kingdom, please be aware that any information you provide to me will be transferred to the United Kingdom. By using my Site, participating in any of my services and/or providing me with your information, you consent to this transfer.

Your Rights With Respect to Your Information

I apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. I recognize all of the rights granted in these regulations, except as limited by applicable law. These rights include:

• Right to Know. You have the right to know what personal information is collected, used, shared or sold. I outline both the categories and specific bits of data I collect, as well as how they are used, in this privacy policy.
• Right of Access. This includes your right to access the personal information I gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
• Right to Correction. You have the right to request correction of your personal information.
• Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from my possession and, by extension, all of my service providers. Fulfillment of some data deletion requests may prevent you from using my services because my applications may then no longer work. In such cases, a data deletion request may result in closing your account.
• Right to Complain. You have the right to make a complaint regarding my handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
• Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: I never have and never will sell your personal data).
• Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
• Right to Portability. You have the right to receive the personal information I have about you and the right to transmit it to another party.
• Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and me, is allowed by applicable law, or is based on your explicit consent.
• Right to Non-Discrimination. This right stems from the CCPA. I do not and will not charge you a different amount to use my products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using my Services.

Many of these rights can be exercised by signing in and directly updating your account information.

If you have questions about exercising these rights or need assistance, please contact me at contact@ashley.how. For requests to delete personal information or know what personal information has been collected, I will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, I will first need written consent with a signature from the account holder before proceeding.

If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.

How I secure your data

All data is encrypted via SSL/TLS when transmitted from my servers to your browser. The database backups are also encrypted.

For products, most data are not encrypted while they live in my database (since it needs to be ready to send to you when you need it), but I go to great lengths to secure your data at rest.

I commit to resolving all complaints

I commit to resolve complaints about your privacy and my collection or use of your personal information. European Union, United Kingdom, or Swiss individuals with inquiries or complaints regarding this privacy policy should contact me at contact@ashley.how.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.gov.uk/data-protection/make-a-complaint.

If your Privacy Shield complaint cannot be resolved through these described channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. To learn more, please view the Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Changes & questions

I may update this policy as needed to comply with relevant regulations and reflect any new practices.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing me at contact@ashley.how and I’ll be happy to answer them!

Adapted from the Basecamp open-source policies / CC BY 4.0