PRIVACY & EMAIL POLICY
Your privacy is very important to us. We want to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet’s vast array of information, tools, and opportunities with complete confidence. 
We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how
“DW LLC” herein known as the “Company” collects information from all end users of our Internet services (the “Services”)-those who access some of our Services but do not have accounts (“Visitors”) as well as those who may purchase Products and/or pay a monthly service fee to subscribe to the Service (“Members”)-what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. We request that you read this Privacy Policy carefully.
Personal Information Our Company Collects and How It Is Used Introduction.
 
Our company collects information in different ways from Visitors and Members who access the various parts of our Services and the network of Web sites accessible through our Service. Registration: Members may be asked to provide certain personal information when they sign up for our Products or Services including name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process is used to manage each Member’s account (such as for billing purposes). This information may be shared with third parties, as stated herein, or in special circumstances. However, in instances where our company and a partner jointly promote our Services, we may provide the partner certain personal information, such as the name, address, and username of persons who subscribed to the Services as a result of the joint promotion for the purpose of offering you other products and services.

In this instance, personal information may not be used by the partner for any other purpose. We may also generate non-identifying and aggregate profiles from personal information Members provide during registration (such as the total number, but not the names, of Members). As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Services. Also, with purchases, we supply our member’s contact information, to our business partners, who then may contact the member by telephone after the member purchase. Sales proceeds are collected by the that business partner company. We also may supply other companies with contact information, for mail offers we believe would be of interest to our members, with or without compensation from those companies. At times we may send an advertisement for a third party product, where we collect the sales proceeds and forward the purchaser’s information to that third party.

Our Company Partners and Sponsors: Some products and services may be offered to Visitors and Members in conjunction with an affiliate, independent contractor seller or non-affiliated partner. To provide Visitors and Members some of these products and services, the partner may need to collect and maintain personal information. Online Shopping: At some Web sites, you can purchase products and services or register to receive materials, such as a newsletter, catalog or new product and service updates. In many cases, you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information.

If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient’s name, address, and phone number. Our company has no control over the third parties’ use of any personal information you provide when placing such an order. Please exercise care when doing so.

If you order services or products directly from our company, we use the personal information you provide to process that order. We do share this information with outside parties that we do business with.Online Advertisements: Our company may display our online advertisements. In those cases we share information about our Visitors and Members collected through the registration process as well as through online surveys and promotions with these advertisers. Additionally, in some instances, we use this information to deliver tailored advertisements or joint ventures. For instance, an advertiser or joint venture company tells us the audience they want to reach and provides us an advertisement tailored to the audience. Based upon the information we have collected, we may then display or send the advertisement to the intended audience. Our company does share personal information about its Visitors or Members with these advertisers or joint venture companies.

Email Policies:
Responses to Email Inquiries: When Visitors or Members send email inquiries to our company, the return email address is used to answer the email inquiry we receive.

Q. Who will have access to your email information?
A. When you subscribe to our single and/or double opt in permission based commercial email newsletter as a website visitor and not as a client, purchaser of a credit card, already existing website membership only club member, an online advertisement winner, you’ll be contacted and provided updates from our company and only our company from time to time. We have stringent protocols put in place to protect user data and only authorized company personal will be sending out permission based electronic email content to website visitors while fully abiding by the can spam as well as GDPR requirements. You can view canspam policies by clicking here (http://en.wikipedia.org/wiki/CAN-SPAM_Act_of_2003)
To use our email services we use the single and/or double opt in email permission based policies with full suppression list requirement.

Q. How will the user be contacted? How often will the user be contacted, will the user be contacted in multiple ways?
A. Usually we like to stay in contact with our email subscribers either on a daily and/or weekly basis by either email, and/or direct mail, radio advertisements, pay per click marketing ads using all paid traffic platforms like google adwords, google search, facebook ads, youtube ads, native ad networks, mobile advertising, just to name a few. We contact you only to keep you informed of any updates, special offers, and other timely information that we find that may be helpful to help you grow your business. You can opt out of any and all of our email newsletters by clicking the link at the bottom of any email you receive from our company by scrolling down to the end of the email and clicking the clearly marked unsubscribe link.

Q. Will this information be sold to third parties?
A. No, under no circumstances do we sell any website visitors information to any third party. We use a single and/or double opt in permission based email system with protocols and are fully can spam complaint along with current GDPR regulations. Your information is secure and safe with us.

Voluntary Customer Surveys: We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to you. We may take the information we receive from individuals responding to our Customer Surveys and combine (or aggregate) it with the responses of other customers we may have, to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our services to you, and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties.

Promotions: Our company may offer polls, contests, sweepstakes, drawings, games, content, or other promotions that are sponsored by or co-branded with third parties. You may be entered in a sweepstakes, contest, or other promotion, simply by making a purchase from us or by providing us with personally identifiable information for some other reason or purpose. Due to these third party relationships, the third parties may obtain personally identifiable information that visitors voluntarily submit to our company. Our company has no control over third parties’ use of this information.

Additionally, personally identifiable information may be collected when you order products, enter contests, vote in polls or otherwise express an opinion, subscribe to one of our services such as our online newsletters, or participate in one of our online forums or communities. The types of personally identifiable information that may be collected at these pages include but may not be limited to: name, address, e-mail address, telephone number, fax number, credit card information, and information about your interests in and use of various products, programs, and services. Our sponsors or third parties may send you material that relates to our company’s services, products or activities.

Special Cases: It is our company’s policy to use or share the personal information about Visitors or Members in ways described herein without additional notice or means to opt out or otherwise prohibit such unrelated uses.

Also, we may disclose personal information about Visitors or Members, or information regarding your use of the Services or Web sites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including: credit agencies, collection agencies, merchant database agencies, law enforcement, or to satisfy laws, such as the Electronic Communications Privacy Act, the Child Online Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Acceptable Use Policy or Terms Of Service, or other user policies; to operate the Services properly; or to protect our company and our Members.

Notice of Compliance to California Residents–Your California Privacy Rights Under The California Online Privacy Protection Act and the California Business and Professions Code This privacy policy identifies the categories of personally identifiable information that our company collects through our Web site or online service, about individual consumers who use or visit our company’s commercial Web site or online service and the categories of third-party persons or entities with whom our company may share that personally identifiable information.
Our company does not maintain a process for an individual consumer who uses or visits our commercial Web site or online service to review and request changes to any of his or her personally identifiable information that is collected through our Web site or online service. See the section below entitled “Revisions To This Policy” for a description of the process by which our company notifies consumers who use or visit our commercial Web site or online service of material changes to our company’s privacy policy for this Web site or online service.
 

The effective date of this privacy policy is listed at the end of this privacy policy under the heading, “Last updated.”
For the purposes of this policy and California compliance the following definitions apply:
Depending on the visitor’s activity, in our commercial Web site or online service, the following “personally identifiable information” may be collected, in addition to information set forth in other sections of this document.
The term “personally identifiable information” means individually identifiable information about an individual consumer collected online by our company from an individual and maintained by our company in an accessible form, and may include any of the

following:
(1) A first and last name.
(2) A home or other physical address, including street name and name
of a city or town.
(3) An e-mail address.
(4) A telephone number.
(5) A social security number.
(6) Any other identifier that permits the physical or online contacting of a specific individual.
(7) Information concerning a user that the Web site or online service collects online, from the user, and maintains in personally identifiable form, in combination with an identifier described within this privacy policy.

Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a
description of the categories of personal information shared. To make such a request, please send an email to
Privacy@PrivacyRequest.com
and please include the phrase “California Privacy Request” in the subject line, the domain name of the Web site you are inquiring about, along with your name, address and email address. We will respond to you within thirty days of receiving such a request.
If you’re residing in Canada or the U.S. you must submit the following request to…

INFORMATION and PRIVACY REQUEST
Please note: A $5.00 application fee is required for all requests.
Make cheque payable to Toronto and Region Conservation Authority.
Request for:
Access to General Records
Access to Own Personal Information
Correction to Own Personal Information
Forward request and fee to:
Information and Privacy Officer
Toronto and Region Conservation Authority
5 Shoreham Dr.
Downsview, ON M3N 1S4
FOI@trca.on.ca
Last name
First name
Middle name
Address
City or Town
Province
Postal Code
Telephone Number (day)
Telephone Number (evening)
E-mail
Detailed description of requested records, personal information or correction of personal information. If request is for correction of personal information, please indicate the desired correction and attach any supporting documentation.
________________________________________________________
________________
To include additional information, attach a separate page.
Preferred method of access to records:
Receive copy
 Examine records onsite



Introduction To GDPR Compliance
"dontewalker.com,,socialmediamarketingaccelerator.com" is committed to providing a superior learning experience for everyone we work with. We know that our users’ are committed to their success and we are equally committed to ensuring that each interaction that someone has with our content is optimized for maximum educational potential. To enable us to do this, "dontewalker.com,,socialmediamarketingaccelerator.com" needs to gather and use certain information about individuals.
Individuals who we gather information about includes customers, affiliates, business contacts, employees, and other people the organization has a relationship with or may need to contact.
This policy describes how this personal data is collected, handled, and stored to meet the company’s data protection standards — and to comply with the law.

Why This Policy Exists
This data protection policy ensures "dontewalker.com,,socialmediamarketingaccelerator.com":
Complies with data protection law and follows industry best practices
Protects the rights of staff, customers, affiliates, and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach
EU General Data Protection Regulation (GDPR) Protection Law

The GDPR (General Data Protection Regulation) protection law describes how organizations who conduct business with individuals or entities located in EU (European Union) nations — including "dontewalker.com,,socialmediamarketingaccelerator.com" — must collect, handle, and store personal information.
These rules apply regardless of whether data is stored electronically, on paper, or in any other manner.
To comply with the law, personal information must be collected and used fairly, stored safely, and not disclosed unlawfully.
The EU GDPR is underpinned by eight core principles. These state that personal data must:
Be processed fairly and lawfully
Be obtained only for specific, lawful purposes
Be adequate, relevant, and not excessive
Be accurate and kept up to date
Not be held for any longer than necessary
Processed in accordance with the rights of data subjects
Be protected in appropriate ways
Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection


1. Policy Statement
Every day our business will receive, use, and store personal information about our customers, affiliates, partners, and colleagues. It is important that this information is handled lawfully and appropriately, in line with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (collectively referred to as the ‘Data Protection Requirements’).
We take our data protection duties seriously, because we respect the trust that is being placed in us to use personal information appropriately and responsibly.


2. About This Policy
This policy and any other documents referred to in it, sets out the basis on which we will process any personal data that we collect or process. This policy does not form part of any employee’s contract of employment and may be amended at any time.
The company as a whole is responsible for ensuring compliance with the Data Protection Requirements and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Officer.


3. What is Personal Data?
Personal data is defined as data, (whether stored electronically or paper based) relating to a living individual who can be identified directly or indirectly from that data, (or from that data and other information in our possession).
Processing is any activity that involves use of personal data. It includes obtaining, recording, or holding the data, organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring personal data to third parties under privacy control conditions.
Sensitive personal data includes contact info, address, session activity on the platform, IP location etc. Sensitive personal data can only be processed under strict conditions, and used for express purpose that it was collected for.


4. Data Protection Principles
Anyone processing personal data, must ensure that data is:
Processed fairly, lawfully and in a transparent manner.
Collected for specified, explicit, and legitimate purposes and any further processing is completed for a compatible purpose.
Adequate, relevant and limited to what is necessary for the intended purposes.
Accurate and where necessary, kept up to date.
Kept in a form which permits identification for no longer than necessary for the intended purposes.
Processed in line with the individual’s rights and in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
Not transferred to people or organizations situated in countries without adequate protection and without firstly having advised the individual.


5. Fair and Lawful Processing
The Data Protection Requirements are not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual.
In accordance with the General Data Protection Regulation (GDPR), we will only process personal data where it is required for a lawful purpose. The lawful purposes include (amongst others): whether the individual has given their consent, the processing is necessary for performing a contract with the individual, for compliance with a legal obligation, or for the legitimate interest of the business. When sensitive personal data is being processed, additional conditions must be met.
Collection of Information
We receive and store information about you such as:
Information you provide us: We collect information you provide to us which includes: your name, email address, address or postal code, payment method, and telephone number. We collect this information in a number of ways, including manual entry while you are using our service, interact with our customer service, participate in surveys or marketing promotions, provide reviews or ratings, taste preferences, set preferences in Your Profile/Account, or otherwise provide information to us through our service or elsewhere.
Information we collect automatically: We collect information regarding you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service.
This information includes:


Your activity on our platform such as course progress and search queries
Details regarding your interactions with customer service such as the date, time and reason for contacting us
Transcripts of any chat conversations that you initiate on our platforms
In the event that you initiate phone support, your phone number
Device IDs or unique identifiers, device and software characteristics (such as type and configuration)
Connection information, statistics on page views, referral URLs, IP address, and standard web log information
Information collected via the use of cookies, web beacons and other technologies, including ad data (such as information on impressions delivered to a cookie, the site URL where the impression was delivered, as well as the date and time).
See our Privacy Policy for more details.

Use of Information
We use the information we collect to provide, analyze, administer, enhance, and personalize our services and marketing efforts, to process your registration, your orders, your payments, and your communication on these and other topics.
Our primary aim is always to enhance the user experience. We do so in several ways using the data that we collect, but a few examples are: determining your general platform usage, required action item completions, login details, etc. which then helps us know what difficulties the you’re facing within the platform, with which can then use to take action to minimize the effort on your end. We collect other information, such as most visited links on our website, which then help us conclude what content was most watched, enabling us to create additional content geared toward our users’ needs and personal preferences.



6. Processing for Limited Purposes
In the course of our business, we may collect and process personal data, which may include data that we receive directly from a data subject and data we receive from other sources including location data, business partners, and subcontractors who work technical, payment and delivery services, credit reference agencies, and other capacities.
We will only process personal data for the specific purposes or for any other purposes specifically permitted by the Data Protection Requirements. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.


7. Notifying Individuals
If we collect personal data directly from an individual, we will inform them about:
The purpose or purposes for which we intend to process that personal data, as well as the legal basis for the processing.
Where we rely upon the legitimate interests of the business to process personal data, the legitimate interests pursued.
The types of third parties, if any, with which we will share or disclose that personal data.
The fact that the business intends to transfer personal data to a non-EEA country or international organization and the appropriate and suitable safeguards in place.
How individuals can limit our use and disclosure of their personal data.
Information about the period that their information will be stored or the criteria used to determine that period.
Their right to request from us as the controller access to and rectification or erasure of personal data or restriction of processing.
Their right to object to processing and their right to data portability.
Their right to withdraw their consent at any time (if consent was given) without affecting the lawfulness of the processing before the consent was withdrawn.
The right to lodge a complaint with the Information Commissioner's Office.
Other sources where personal data regarding the individual originated from and whether it came from publicly accessible sources.
Whether the provision of the personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the individual is obliged to provide the personal data and any consequences of failure to provide the data.
The existence of automated decision-making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the individual.
If we receive personal data about an individual from other sources, we will provide them with this information as soon as possible (in addition to telling them about the categories of personal data concerned) but at the latest within One (1) month.
We will also inform data subjects whose personal data we process, that we are the data controller with regard to that data and our contact detail regarding data protection act is support@dontewalker.com, and who the Data Protection Compliance Manager/Data Protection Office is.


8. Adequate, Relevant and Non-Excessive Processing
We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.


9. Accurate Data
We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.


10. Timely Processing
We will not keep personal data longer than necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy or erase from our systems, all data which is no longer required.


11. Processing in line with Data Subject’s Rights
We will process all personal data in line with data subjects’ rights, in particular their right to:
Confirmation as to whether or not personal data concerning the individual is being processed.
Request access to any data held about them by a data controller.
Request rectification, erasure or restriction on processing of their personal data.
Lodge a complaint with a supervisory authority.
Data portability.
Object to processing including for direct marketing.
Not be subject to automated decision making including profiling in certain circumstances.


12. Data Security
We will take appropriate security measures against unlawful or unauthorized processing of personal data and against the accidental or unlawful destruction, damage, loss, alteration, or unauthorized disclosure of or access to personal data transmitted, stored, or otherwise processed.
We will put in place procedures and technologies to maintain the security of all personal data from the point of the determination of the means for processing and point of data collection to the point of destruction. Personal data will only be transferred to a data processor if he or she agrees to comply with those procedures and policies, or if he or she puts in place adequate measures himself/herself.
We will maintain data security by protecting the confidentiality, integrity, and availability of the personal data, defined as follows:
Confidentiality: Only people who are authorized to use the data can access it.
Integrity: Personal data should be accurate and suitable for the purpose for which it is processed.
Availability: Authorized users should be able to access the data if they need it for authorized purposes. Personal data should therefore be stored on the "dontewalker.com,,socialmediamarketingaccelerator.com" central computer system & databases instead of individual PCs.

Our Security Procedures:
Entry controls: Any stranger seen in entry-controlled areas will be reported.
Securing lockable desks and cupboards all the time. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
Data minimization will be practiced.
Pseudonymization and encryption of data will be the primary state of storing the data.
Methods of disposal: Paper documents would be shredded. Digital storage devices would be physically destroyed when they are no longer required.
Electronic data would be deleted once it’s intended purpose is fulfilled.
Equipment: Staff has to ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
Transferring Personal Data Outside of the EEA: We may transfer any personal data we hold to a country outside the European Economic Area (‘EEA’) or to an international organization, provided that one of the following conditions applies:
The country to which the personal data is transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.
The data subject has given his consent.
The transfer is necessary for one of the reasons set out in the Act, including the performance of a contract between us and the data subject, or to protect the vital interests of the data subject.
The transfer is legally required on important public interest grounds or for the establishment, exercise or defense of legal claims.
The transfer is authorized by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.
Subject to the requirements above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Those staff may be engaged in, among other things, the fulfillment of contracts with the data subject, the processing of payment details and the provision of support services.


14. Disclosure and Sharing of Personal Data
We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in: https://www.legislation.gov.uk/ukpga/2006/46/section/1159


15. Subject Access Requests
To these ends, the company has a privacy statement setting out how data relating to individuals is used by the company.
Individuals must make a formal request for information we hold about them. Employees who receive a request should forward it to the data department immediately.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
We will check the caller’s identity to make sure that information is only given to a person who is entitled to it.
We will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.
Where a request is made electronically, data will be provided electronically when possible.
Our support team will refer a request to the data processing department or the Data Protection Compliance Manager for assistance in difficult situations.


16. Changes to this Policy
We may modify this Privacy Statement at any time, but we will provide prominent advance notice of any material changes to this Statement, such as posting a notice through the Services, on our websites, or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using the Services.
DW LLC
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