Private Policy

And as the following website(s) and social media identities:
www.artichokedove.com
Instagram: @artichokedove
Facebook: @artichokedove

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Email contact details:
bruce@artichokedove.com

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There are two sections to the following information:

• About your personal data: the type of data that is collected or used, including when, how and why

• Your rights: all the ways that you can control what happens with your data

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About your personal data
When you make an inquiry regarding private sessions, mentoring, coaching or for taking any of the trainings I offer: The name and contact details you give and the content of your message(s) are retained for any one of three reasons:

• By your consent

• As part of a ‘contract’ (only while we communicate)

• For legitimate future business interests and interactions – for good business practice I keep tabs on who has made contact before, the types of questions asked, etc.

 

When you register for or attend an in-person workshop or training or online coaching/mentoring services:
All of the above applies. I / Artichoke Dove also keeps record of your name, email address, mailing address, record of you attendance, your certificates earned etc. on the legal bases of both contract and legitimate interest – so that I / Artichoke Dove can confirm your certificate status / reissue certification if required, also so that we can send you updates or offers which may be of specific interest to you as an attendee/graduate.

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When you work privately with Bruce Whittemore on an individual basis (private sessions and or mentoring): Private Client work is different. Dependent on the work, you may wish (or need) to provide personal details of a sensitive nature.
Client forms are retained in electronic, printed or handwritten format and will include your contact details and where appropriate, signature. The sensitive nature of such documents will generally be in relation to the issues and concerns that you are seeking assistance and support for. As session notes, these are scant memos handwritten for the purpose of fulfilling our contract and keeping tabs on the work during the session and from one week to the next, filed separately with only initials and date as identifiers so that no other person may connect these details alone to your personal identity. These are kept only on paper and stored under locked file cabinet or maintained digitally on an external hard drive in a specific client file. These records are kept during the time that the individual is under active coaching or mentoring.
 
Anonymous Information: I collect certain technical and routing information about your computer, which is automatically submitted to us by your browser and does not personally identify you. This information may include browser type, operating system and CPU speed, your IP address, and search requests and results. I may also track your use of the site, including pages visited and the time spent on each page. The purpose of collecting this information is to provide you with the best possible service, to ensure the accuracy and efficiency of my search engine, and to measure the use of this website and to improve its content and performance. To the extent I share such information with third parties; it is not traceable to any particular user and will not be used to contact you.

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Sharing your data: Your privacy is important and I do not sell your data nor share it except by your consent or under the law.
When working together, I may give out elements of your personal information to another practitioner or therapist as part of a referral. This will always only be with your personal consent. In continuation of current US laws on confidentiality I also retain the right and in some cases the legal requirement to breach confidentiality to inform an authority such as the police or your GP of impending harm or illegality.

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Third Party Links: Third parties that link on this site may use cookies or collect other information when you go to their site. I do not control the collection or use of your information by these companies. You should contact these companies directly if you have any questions about their collection or use of information about you.

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Personally Identifiable Information: The only personally identifiable information I collect is that which you voluntarily provide. I will use this information in order to send you emails regarding offers, products, and services I think may interest you. I may also use it to conduct marketing research, and improve my products and services. When you submit personally identifiable information to me, you understand that you are agreeing to allow me to access, store, and use it for those purposes. I may share this information with third parties, but only those parties I trust to help us run our website and online business, and who agree to keep your information confidential. We may also provide this information if requested by law enforcement upon receipt of the appropriate documentation. 

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Financial Information: Through this website I may sell products and services. In order to purchase our products and services you will be asked to provide financial information. Typically, this information will be collected by a third-party provider. In the event that the information is collected by me, I will not disclose your financial information to anyone unless required to do so by court order. When you make an online, mailed or in person purchase for a product or service (i.e. private sessions, in-person or online workshop registration, an ongoing course membership or subscription), this is a contract for services. Your contact details are dealt with as above (consent, contract, and legitimate reasons) – also these: your purchase history and the payment details (i.e. sent to us from PayPal/Venmo) are retained for seven years for legal and accounting IRS reasons.

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Opt-Out Policy: If at any time you do not wish to receive offers and e-mails from meus, I ask that you tell me. There will be instructions to opt-out of my mailing list on the emails you receive from me. 

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Security: I take measures to maintain the security of the personal information you have provided to me. Even so, I cannot guarantee that all information shared through the internet will remain secure and you agree that I am not responsible for any unauthorized, inadvertent disclosure.
 

Children’s Privacy: This site is not meant for children under the age of 18 years old. I do not knowingly collect information pertaining to or market to children under the age of 18 years old. If working with children under the age of 18 it is through parental agreement and the same guidelines are followed as outlined above.

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Transfer of Customer Information: Company customer lists and information are considered business assets and as such, in the event that I merge with another entity or if I sell my assets to another entity, my business assets, including my customer lists and information, would be transferred to that entity.

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Your Rights
Right to be informed
You have the right to be informed about the collection and use of your personal data.
I must provide you with information including: my purposes for processing your personal data, retention periods for that personal data, and who it will be shared with. This ‘privacy information’ is provided above.
I must provide you with privacy information at the time I collect your personal data from you, in other words, it has to be available to you before you fill in a form or hand over your data such as your email address and will be easily available on our websites.
If I obtain your personal data from other sources, e.g. by referral or from the payment service provider your selected, I must provide you with privacy information within a reasonable period of obtaining the data and no later than one month.
There are a few circumstances when I do not need to provide people with privacy information, such as if an individual already has the information or if it would involve a disproportionate effort to provide it.
The information I provide to people must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language. Therefore if there is anything you do not understand, please get in touch.
 
Right of access
You have the right to access your personal data and supplementary information. This allows you to be aware of and verify the lawfulness of the processing.
You are entitled to confirmation that your data is being processed, access to your personal data, and other supplementary information as provided in this privacy notice.
 
Right to rectification
You have the right to have the data your personal data corrected if it is incorrect, or completed if it is incomplete.
 
Right to erasure
You may request, verbally or in writing, to have your data erased. This is also commonly known as ‘the right to be forgotten’. This right only takes effect when:
Your personal data is no longer necessary for the purpose for which it was originally collected or processed,
You withdraw your consent when the sole legal basis to hold this information is your consent,
There is a legitimate interest in processing this data, which does not override your request
Processing/analyzing of the personal data was for direct marketing purposes and this is the use you object to:
Your personal data was processed unlawfully without a proper legal basis
There is a legal obligation to comply with your request
 
Right to restrict processing
You have the right to request the restriction or suppression of your personal data. In other words you want to stop the data being used but keep it on file.
In this case your personal data cannot be used and can only be stored unless:
You give your consent;
It is for the establishment, exercise or defense of legal claims;
It is for the protection of the rights of another person (natural or legal); or
It is for reasons of important public interest.
 

Right to data portability
This allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. Doing this is meant to enable you to take advantage of applications and services that can use this data to find you a better deal or help you understand your spending habits. In general this rule exists for data held by big service providers, such as your call history or insurance or gas bill history. The right also only applies to information you have provided.
If, as a private client you wish to carry a copy of your case notes or other sensitive data to another practitioner or other mental, physical or spiritual health service, provided these may be provided to you or to the nominated service provider, on request, as an encrypted and password protected document.
 
Right to object
Individuals have the right to object to:

Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);

Direct marketing (including profiling); and

Processing for purposes of scientific/historical research and statistics 

Your objection must be made on grounds relating to your particular situation.

Once you object your data can no longer be processed, unless:

There are demonstrably compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or

The processing is for the establishment, exercise or defense of legal claims.

You may complain directly to me using the contact details above. 
 
You may of course also exercise your right to legal action.
Timelines:
You can claim a right verbally or in writing.
A response should come without delay and at least within one month of receipt. The time limit is calculated from the day after you make the request (whether the day after is a working day or not) until the corresponding calendar date in the next month.
I aim to respond within 28 days.
Exceptions:
When you request access to your data, a copy must be provided free of charge. However, you can be charged a ‘reasonable fee’ when a request is:
Manifestly unfounded or excessive, particularly if it is repetitive, unless that’s because I failed to respond; or
For further copies of the same information (that’s previously been provided).

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Contact: Should you have questions regarding this Privacy Policy, please contact: bruce@artichokedove.com