Type of website: Ecommerce
Effective date: December 15, 2023

David
T.E.Foster (the “Site”) is owned and operated by Headspring Consulting
Inc. If you have additional questions after reviewing this privacy
policy, or would like to make a complaint, please contact Sandra Foster
by e-mail at fosters@headspringconsulting.com

Contact information:

PURPOSE:

This
Privacy Policy describes how David T.E. Foster (the “Site” or “we”)
collects, uses, and discloses your Personal Information when you visit
or make a purchase from the Site.

This Privacy Policy applies in addition to the terms and conditions of our Site.

CONSENT

By using our Site users agree that they consent to the conditions set out in this Privacy Policy.

When
you provide us your personal data for processing, you are giving us
legal consent to perform that processing. You may withdraw your consent
at any time. However, if you withdraw your consent, it will not undo any
processing completed before you withdrew your consent, or make that
processing unlawful.

You can withdraw your consent by contacting us via email, contact form, or by unsubscribing from our emails.

LEGAL BASIS FOR PROCESSING

We
collect and process personal data about users only when we have a legal
basis for processing and rely on the following legal basis to collect
and process the personal data of users:

• Users have provided their consent to the processing of their data for one or more specific purposes

SECTION 1: COLLECTING PERSONAL INFORMATION

When
you visit the Site, we collect certain information about your device,
your interaction with the Site, and information necessary to process
your purchases. We may also collect additional information if you
contact us for customer support. In this Privacy Policy, we refer to any
information about an identifiable individual (including the information
below) as “Personal Information”.

Personal Data We Collect

We
only collect data that helps us achieve the purpose set out in this
Privacy Policy. We will not collect any additional data beyond the data
listed below without notifying you first.

We collect information about your Device Information as follows:

• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose: shared
  with our shop processor, WooCommerce, our shipping providers, and if
  you elect to sign up for our newsletter, our newsletter service
  provider, MailChimp
• Personal Information collected: version
  of web browser, IP address, location and time zone, cookie information,
  clicked links, visited pages, abandoned carts/checkouts, and other
  activities that describe how you interact with the Site 

We collect information about your Order as follows:

• Purpose of collection: to
  provide products or services to you to fulfill our contract, to process
  your payment information, arrange for shipping, and provide you with
  invoices and/or order confirmations, communicate with you, screen our
  orders for potential risk or fraud, and when in line with the
  preferences you have shared with us, provide you with information or
  advertising relating to our products or services.
• Source of collection: collected from you.
• Disclosure for a business purpose: shared
  with our shop processor, WooCommerce, our shipping providers, and if
  you elect to sign up for our newsletter, our newsletter service
  provider, MailChimp
• Personal Information collected: name,
  billing address, shipping address, payment information (including
  credit card numbers, debit cards, Venmo or PayPal emails, etc.), email
  address, and phone number.

We collect Customer Support Information as follows:

• Purpose of collection: to
  aid in resolving any customer inquiries or issues in a timely manner,
  communicate updates about previous orders, and when in line with the
  preferences you have shared with us, update you on newly released
  products.
• Source of collection: collected from you.
• Disclosure for a business purpose: when in line with the preferences you have shared with us, shared with our newsletter service provider, MailChimp

SECTION 2: SHARING PERSONAL INFORMATION

We
will not sell or share your data with other third parties, except to
help us provide services and fulfill our contracts with you, and in the
following cases :

• We use WooCommerce to power our online store.
• We use various third-party merchandise fulfilment providers to get your items.
• We use MailChimp to power our newsletter.
• We use a variety of shipping providers to ship your orders, including Stallion Express, Canada Post, USPS and UPS.
• We
  may share your Personal Information to comply with applicable laws and
  regulations, to respond to a subpoena, search warrant or other lawful
  request for information we receive, or to otherwise protect our rights.
  If this occurs, you will be notified via the email we have on record for
  you.

Links to other websites

If
you follow hyperlinks from our Site to another Site, please note that
we are not responsible for and have no control over their privacy
policies and practices.

Our
website may contain links to other websites of interest. However, once
you have used these links to leave our site, you should note that we do
not have any control over that other website. Therefore, we cannot be
responsible for the protection and privacy of any information which you
provide whilst visiting such sites and such sites are not governed by
this privacy statement. You should exercise caution and look at the
privacy statement applicable to the website in question.

 SECTION 3: USING PERSONAL INFORMATION

We
use your personal Information to provide our services to you, which
includes: offering products for sale, processing payments, shipping and
fulfillment of your order, and keeping you up to date on new products,
services, and offers

Lawful Basis

We process your personal information under the following lawful bases:

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

 SECTION 4: RETENTION OF YOUR PERSONAL INFORMATION

When
you place an order through the Site, we will retain your Personal
Information for our records unless and until you ask us to erase this
information. For more information on your right of erasure, please see
the ‘Your Rights’ section below.

AUTOMATIC DECISION MAKING

You
have the right to object to processing based solely on automated
decision-making (which includes profiling), when that decision-making
has a legal effect on you or otherwise significantly affects you.

We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our
processor WooCommerce uses limited automated decision-making to prevent
fraud that does not have a legal or otherwise significant effect on
you.

Services that include elements of automated decision-making include:

• Temporary
  blacklist of IP addresses associated with repeated failed transactions.
  This blacklist persists for a small number of hours.
• Temporary
  blacklist of credit cards associated with blacklisted IP addresses.
  This blacklist persists for a small number of days.

STORAGE DURATION

User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

HOW WE PROTECT YOUR DATA

We
are committed to ensuring that your information is secure. To minimize
unauthorised access or disclosure, we have put in place suitable
physical, electronic, and managerial procedures to safeguard and secure
the information we collect online.

While
we take all reasonable precautions to ensure that user data is secure
and that users are protected, there always remains the risk of harm. The
Internet as a whole can be insecure at times and therefore we are
unable to guarantee the security of user data beyond what is reasonably
practical.

 SECTION 5: YOUR RIGHTS

You
have the right to ask that your Personal Information be corrected,
updated, or erased. If you would like to exercise these rights, please
contact us through the contact information listed at the beginning of
this policy. 

Your
Personal Information will be initially processed in Canada  and then
transferred outside of Canada for storage and further processing,
including to Europe and the United States.

CCPA

If
you are a resident of California, you have the right to access the
Personal Information we hold about you (also known as the ‘Right to
Know’), to port it to a new service, and to ask that your Personal
Information be corrected, updated, or erased. If you would like to
exercise these rights, please contact us through the contact information
above. 

You can view more details about your CCPA rights in our CCPA Privacy Policy.

Children

We
do not knowingly collect or use personal data from children under 16
years of age. If we learn that we have collected personal data from a
child under 16 years of age, the personal data will be deleted as soon
as possible. If a child under 16 years of age has provided us with
personal data their parent or guardian may contact our privacy officer.

Access, Modify, Delete, or Challenge the Data Collected

If
you would like to know if we have collected your personal data, how we
have used your personal data, if we have disclosed your personal data
and to who we disclosed your personal data, if you would like your data
to be deleted or modified in any way, or if you would like to exercise
any of your other rights under this privacy policy and applicable laws
& regulations, please contact us.

Opt-Out of Data Collection, Use or Disclosure

In addition to the method(s) described in the above section Access, Modify, Delete, or Challenge the Data Collected,
we provide the following specific opt-out methods for the forms of
collection, use, or disclosure of your personal data specified below:

• You
  can opt-out of the use of your personal data for marketing emails. You
  can opt-out by clicking “unsubscribe” on the bottom of any marketing
  email

SECTION 6: COOKIES

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. Its purpose is to collect data relating to the user’s browsing habits. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies.

Cookies
make your browsing experience better by allowing the website to
remember your actions and preferences (such as login and region
selection). This means you don’t have to re-enter this information each
time you return to the site or browse from one page to another. Cookies
also provide information on how people use the website, for instance
whether it’s their first time visiting or if they are a frequent
visitor.

We use the following types of cookies on our Site:

Analytical cookies: Analytical
cookies allow us to improve the design and functionality of our Site by
collecting data on how you access our Site, for example data on the
content you access, how long you stay on our Site, etc; and 

Third-Party Cookies: Third-party cookies are created by a website other than ours.

HOW WE USE COOKIES

A
cookie is a small file which asks permission to be placed on your
computer’s hard drive. Once you agree, the file is added, and the cookie
helps analyse web traffic or lets you know when you visit a particular
site. Cookies allow web applications to respond to you as an individual.
The web application can tailor its operations to your needs, likes, and
dislikes by gathering and remembering information about your
preferences.

We
use traffic log cookies to identify which pages are being used. This
helps us analyse data about webpage traffic and improve our website in
order to tailor it to customer needs. We only use this information for
statistical analysis purposes and then the data is removed from the
system.

Overall,
cookies help us provide you with a better website by enabling us to
monitor which pages you find useful and which you do not. A cookie in no
way gives us access to your computer or any information about you,
other than the data you choose to share with us.

Certain cookies are necessary for the functioning of the store.

You
can choose to accept or decline cookies. Most web browsers
automatically accept cookies, but you can usually modify your browser
setting to decline cookies if you prefer. This may prevent you from
taking full advantage of the website