Privacy Policy - Steven Milanese

Last Updated: November 2024

Introduction

Welcome to StevenMilanese.com (the “Site”), operated by Steven Milanese (“we,” “us,” “our,” or the “Company”). We are committed to protecting your personal information and respecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our Site or use any of our services, applications, or platforms (collectively, the “Services”). Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

1. Information We Collect

1.1 Personal Information

We collect various types of personal information, including but not limited to:

1.1.1 Contact and Identity Information

Full name and preferred name
Email address(es)
Postal address and shipping address
Telephone number(s)
Date of birth
Gender (if you choose to provide it)
Professional title and company affiliation

1.1.2 Account Information

Username and password
Account preferences and settings
Profile picture (if you choose to upload one)
Security questions and answers
Account activity history
Login timestamps and locations

1.1.3 Financial Information

Payment card details (processed securely through third-party providers)
Transaction history
Billing address
Purchase history and preferences
Subscription status and history

1.1.4 Communication Data

Correspondence content and metadata when you contact us
Customer service interactions
Chat logs and transcripts
Survey responses and feedback
Comments and forum posts
Support ticket information

1.2 Automatically Collected Information

1.2.1 Device and Technical Information

IP address and geolocation data
Device identifiers (e.g., MAC address)
Browser type and version
Operating system and platform
Screen resolution and color settings
Language preferences
Time zone settings

1.2.2 Usage Data

Access times and dates
Pages viewed and navigation patterns
Referring and exit pages
Click patterns and interaction data
Time spent on pages
Search queries
Error logs
Performance data

1.2.3 Cookies and Tracking Technologies

Session cookies
Persistent cookies
Web beacons
Pixel tags
Local storage objects
Mobile advertising identifiers

1.2.4 Analytics Data

Traffic sources
User behavior patterns
Conversion tracking
A/B testing results
Heat maps
Session recordings (anonymized)
Performance metrics

1.3 Information from Third Parties

1.3.1 Social Media Data

Profile information from connected social media accounts (with your consent)
Social media handles and interactions
Shared content and preferences

1.3.2 Third-Party Service Providers

Payment processor information
Shipping and fulfillment data
Marketing and advertising data
Analytics provider insights

1.3.3 Public Sources

Public records
Professional directories
Published works
Public social media profiles

2. How We Use Your Information

2.1 Core Service Provision

Account Creation and Maintenance: To set up and manage your account.
Authentication and Security: To verify your identity and protect against unauthorized access.
Service Delivery: To provide the Services you request.
Transaction Processing: To process payments and fulfill orders.
Customer Support: To respond to your inquiries and provide assistance.
Service Improvement: To analyze usage patterns and improve our Services.
Content Personalization: To tailor content and recommendations to your interests.

2.2 Communication and Marketing

Service Updates: To inform you about changes or updates to our Services.
Marketing Communications: To send promotional materials (with your consent).
Event Invitations: To invite you to events or webinars.
Feedback Collection: To request your feedback through surveys.

2.3 Analysis and Improvement

Usage Analysis: To monitor and analyze usage trends.
User Experience Optimization: To enhance the functionality and user-friendliness of our Services.
Feature Development: To develop new products, services, or features.

2.4 Legal and Compliance

Fraud Prevention: To detect and prevent fraudulent activities.
Legal Obligations: To comply with applicable laws and regulations.
Dispute Resolution: To address and resolve any disputes or legal claims.

2.5 Business Operations

Strategic Planning: To make informed business decisions.
Market Research: To conduct research and analyze market trends.
Performance Reporting: To generate reports for internal use.

3. Legal Bases for Processing

3.1 Consent-Based Processing

We process your personal information based on your consent for:

Marketing communications
Use of non-essential cookies
Sharing data with third parties for marketing purposes (with your explicit consent)

3.2 Contractual Necessity

Processing is necessary to:

Fulfill our contract with you
Provide and manage your access to our Services
Process payments and transactions

3.3 Legal Obligations

We process your data to comply with legal obligations, such as:

Tax reporting
Financial record-keeping
Responding to legal requests

3.4 Legitimate Interests

We process your information for our legitimate interests, provided they do not override your rights:

Fraud prevention and security
Service improvement and analytics
Direct marketing (where permitted by law)

4. Disclosure of Your Information

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

Hosting providers
Payment processors
Analytics services
Email and communication platforms
Customer support systems

4.2 Business Partners

We may share information with trusted business partners for:

Joint marketing activities
Co-sponsored events or promotions

4.3 Legal and Regulatory

We may disclose your information to:

Law enforcement agencies
Regulatory bodies
Government authorities
Professional advisors (e.g., lawyers, accountants)

4.4 Corporate Transactions

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity.

5. International Data Transfers

5.1 Transfer Mechanisms

Your information may be transferred to and processed in countries outside of your country of residence. We use appropriate safeguards, such as:

Standard Contractual Clauses approved by the European Commission
Data processing agreements with our service providers

5.2 Transfer Safeguards

We implement measures to protect your data during international transfers, including:

Encryption
Access controls
Data minimization

6. Data Retention

6.1 Retention Periods

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Account Information: Retained for the duration of your account plus 7 years.
Transaction Records: Retained for 7 years for tax and accounting purposes.
Communication Records: Retained for 3 years.

6.2 Retention Criteria

Our retention periods are determined based on:

Legal obligations
Business needs
Contractual requirements

6.3 Data Deletion

When your personal information is no longer required, we will securely delete or anonymize it.

7. Your Rights

7.1 Access Rights

You have the right to request:

Access to the personal data we hold about you
Information about how your data is processed

7.2 Rectification Rights

You can request correction of any inaccurate or incomplete personal data.

7.3 Erasure Rights

You have the right to request the deletion of your personal data under certain circumstances.

7.4 Portability Rights

You can request a copy of your personal data in a structured, commonly used, and machine-readable format.

7.5 Objection Rights

You have the right to object to:

Processing based on legitimate interests
Direct marketing purposes

7.6 Restriction Rights

You can request that we restrict the processing of your personal data under certain conditions.

To exercise any of these rights, please contact us using the information provided in the Contact Us section.

8. Security of Your Information

8.1 Technical Measures

We employ various security measures to protect your information, including:

Encryption of data in transit and at rest
Secure socket layer (SSL) technology
Firewalls and intrusion detection systems
Regular security assessments

8.2 Organizational Measures

Access is limited to authorized personnel
Staff training on data protection
Policies and procedures for data handling

8.3 Physical Security

Secure facilities with controlled access
Environmental safeguards
Secure disposal of physical records

9. Cookies and Similar Technologies

9.1 Cookie Types

We use cookies to enhance your experience, including:

Essential Cookies: Necessary for the operation of our Site.
Analytics Cookies: Help us understand how visitors interact with our Site.
Advertising Cookies: Used to deliver relevant ads.

9.2 Cookie Management

You can manage your cookie preferences through your browser settings. However, disabling cookies may affect the functionality of our Services.

9.3 Tracking Technologies

We also use:

Web beacons
Pixel tags
Local storage

These technologies help us analyze trends and administer the Site.

10. Additional Privacy Considerations

10.1 Special Categories of Data

We do not intentionally collect special categories of personal data, such as:

Health information
Biometric data
Religious beliefs

10.2 Automated Decision Making

We do not use automated decision-making processes that have legal or significant effects on you.

10.3 Privacy by Design

We incorporate data protection into the development of our business processes and systems.

11. Changes to This Privacy Policy

11.1 Update Procedures

We may update this Privacy Policy periodically. Changes will be posted on this page with an updated “Last Updated” date.

11.2 Communication Methods

Significant changes may be communicated via:

Email notifications
Prominent notices on our Site

12. Contact Us

12.1 Contact Methods

If you have any questions or concerns about this Privacy Policy or our practices, please contact us:

Email: [email protected]
Contact Form: https://stevenmilanese.com/#contact

12.2 Response Procedures

We aim to respond to all inquiries within 30 days.

13. Definitions

Personal Data: Any information relating to an identified or identifiable natural person.
Processing: Any operation performed on personal data.
Controller: The entity that determines the purposes and means of processing personal data.

14. Jurisdiction-Specific Provisions

14.1 European Union (GDPR)

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR), including the right to lodge a complaint with a supervisory authority.

14.2 California (CCPA/CPRA)

For California residents, this Privacy Policy is intended to comply with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). You have the right to:

Know the categories of personal information we collect
Request deletion of your personal information
Opt-out of the sale of your personal information (we do not sell personal data)

To exercise these rights, please contact us.

14.3 Other Jurisdictions

Residents of other jurisdictions may have additional rights under local laws. Please contact us for more information.

Disclaimer: This Privacy Policy is provided for informational purposes only and does not constitute legal advice. We recommend consulting with qualified legal counsel to ensure compliance with all applicable laws and regulations in your jurisdiction. This policy was last reviewed by legal counsel on November 1, 2024.