Privacy Policy

Modification Date: May 27, 2018

Effective Date: June 27, 2018

1. If You are in the EU

What Personal Data Do We Collect from You?

Personal data is information that can be used to identify you such as your name, IP address, and email address. As a business, we collect personal data from you in many ways, including:

(1.) Opt-In to Email Newsletter: Your first name and email address.

(2.) Opt-In to Tools: Your first name and email address.

(3.) Contact Form: Your first name and email address.

What Is the Purpose of Processing Your Personal Data?

We collect the information above for the following purposes.

(1.) Opt-In to Email Newsletter: To provide you with information on personal finance and other related content.

(2.) Opt-In to Tools: To send you electronic personal finance tools that you are interested in.

(3.) Contact Form: To answer questions you might have for us.

What Legal Basis Do We Have for Collecting and Processing Your Information?

Websites must have a legal basis for collecting information from individuals located in the European Union. Our legal basis for each of the ways we collect information from you is as follows. Please note, where consent forms the basis, you can withdraw consent at any time by contacting Erica Gellerman or opting out of an email message using the unsubscribe link.

(1.) Opt-In to Email Newsletter: We will ask for your consent first.

(2.) Opt-In to Tools: We will ask for your consent first.

(3.) Contact Form: We have an allowed legitimate interest in providing a response to your questions and need to use your data to do so. We will not use the data for other purposes.

“Legitimate interests” for processing your personal information exist where you submit the information with an expectation that it will be processed and there is no undue impact on you. If you disagree or have questions, please contact Erica Gellerman at erica@therworthproject.co and we will cease the processing of your data under this legal basis.

Who Has Access to The Data We Collect?

We process and have access to the data we collect from you. However, we use third parties to assist us with processing your personal data including the following categories of recipients:

Financial transaction processors (processing your payments)
Customer service communication platform
Contest and survey platform
Email communication manager
Marketing funnel providers
Website management services
Website design and programming services

These third parties have signed contracts with us in which they are prohibited from utilizing, sharing or retaining your personal data for any purpose other than we dictate.

Cookies and Similar Technologies

This site uses cookies and similar technologies to track aspects of you and other people who visit us. This tracking is done to provide us with information on how people move about the site, what is of interest to them and what is not, how our marketing is performing, and incidental items such as what percentage of users access the site from a personal computer versus a mobile phone. You may block most cookies by adjusting your browser settings as well as responding to the cookie consent notice that appears when you visit this site.

How Long Do We Keep Your Data?

We keep your personal data for different periods of time depending on the reason it was gathered in the first place.

(1.) Opt-In to Email Newsletter: 5 years

(2.) Opt-In to Tools: 5 years

(3.) Contact Form: 24 months

If a legal claim arises involving your data, we will store and disclose that data until the matter is resolved.

Your Right to Ask for Corrections, Erasure, And Export Of Your Data

You have the right to control your personal data. Specifically, you have the following rights:

The right to be informed: We are informing you now with this policy.
The right of access: We’ll provide you with the data we have about you.
The right to rectification: Request we fix incorrect data about you.
The right to erasure: Request we erase certain data about you.
The right to restrict processing: Ask us to restrict certain type of processing of your personal information.
The right to data portability: Ask us to provide your personal data we have for export.
The right to object: Object to how we use your data.
Rights in relation to automated decision making and profiling: We don’t profile you, but keep in mind you have this right with other sites.

To exercise any of these rights, please contact Erica Gellerman at erica@theworthproject.co with your request.

Your Right to Withdraw Consent

Although this is mentioned above, we want to emphasize that wherever we’ve asked for your consent to collect or process your personal data, you have the right to withdraw that consent. If you receive email messages from us, you can use the “unsubscribe” link in each message to withdraw consent and stop the mailings.

Alternatively, you can contact Erica Gellerman at erica@theworthproject.co with your request.

Do We Transfer Your Data to Third Countries?

No. We are based in the United States. Your data is collected and held here.

Privacy Concerns, Contacting Us, and Complaints.

You can contact Erica Gellerman at erica@theworthproject.co with any questions or requests you have about these policies or your personal data. If, after contacting us, you feel a privacy issue has not be resolved, you have the right to file a complaint with a Supervisory Authority such as the Data Protection Commissioner of Ireland.

Data Controller

Representative: Erica Gellerman

Gellerholz, LLC: theworthproject.co

PO Box 6046

San Ramon, CA 94583

2. If You are in California

Do Not Track Signals

Pursuant to the California Online Privacy Protection Act, we hereby disclose we honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

California Eraser Law

If you are an individual under 18 and have provided personal information or content to us in some manner, you have the right to request the deletion of that information pursuant to the “California Eraser Law.” Contact us to make such a request at erica@theworthproject.co.

3. Regardless of Location

How do we protect your information?

We do not use vulnerability scanning and/or scanning to PCI standards. An external PCI compliant payment gateway handles all CC transactions. We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Understand and save user’s preferences for future visits.

• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since every browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, some of the features that make your site experience more efficient may not function properly. It won’t affect the user’s experience that makes your site experience more efficient and may not function properly.

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our homepage or at a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

• On our Privacy Policy Page

Can change your personal information:

• By emailing Erica Gellerman at the erica@theworthproject.co to request a change or sending a letter at the address at the bottom of the page.

Does our site allow third-party behavioral tracking?

It’s also important to note that we allow third-party behavioral tracking.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify you via email

• Within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions

• Process orders and to send information and updates pertaining to orders.

• Send you additional information related to your product and/or service

• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CAN-SPAM, we agree to the following:

• Not use false or misleading subjects or email addresses.

• Identify the message as an advertisement in some reasonable way.

• Include the physical address of our business or site headquarters.

• Monitor third-party email marketing services for compliance, if one is used.

• Honor opt-out/unsubscribe requests quickly.

• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at

• Follow the instructions at the bottom of each email or email Erica Gellerman at erica@theworthproject.co.

and we will promptly remove you from ALL correspondence.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below.

Gellerholz, LLC