CRLC seeks to make literary art accessible in a safe space for writers, and participants choose to be part of a literary community hosted online, using Automattic web development products:
- WordPress offers the design, features, and support to bring a website to life.
- Jetpack provides website connections to features and tools available through WordPress.com.
- Polldaddy is a tool to customize quizzes, surveys, and polls.
- Intense Debate provides tools to manage comments on the website.
- Akismet helps control spam through filters that sometimes catch non-spam.
Currently, CRLC does not use any plug-ins, but PayPal, Mail Chimp, and Survey Monkey are tools the buckaroo employs for business and communication. All require users to sign in or sign up. A subscriber, patron, client on retainer, or project writer (for a contest, anthology or other literary project writer agreed to participate in) can opt out of emails or e-newsletters.
Currently, CRLC does not use AdWords, Amazon Affiliate, or any other third-party entity. Ads at CRLC consist mostly of links to community author book sales, and occasionally ads highlight events or sponsors). At no time is participant data shared with any advertising entities, including those also in the literary community.
Who We Are and What This Policy Covers
CRLC hosts a free weekly literary challenge open to all writers who chose to participate through our platform. We host an annual contest, publish collaborative projects, provide writer developments, and other free support and information to writers around the world. Charli Mills also provides client services and opportunities for patrons and sponsors of literary art. Our mission is to make literary art accessible.
- Our website (including automattic.com, wordpress.com, jetpack.com, polldaddy.com, gravatar.com, intensedebate.com, akismet.com and surveymonkey.com);
- Our mobile applications (including the WordPress mobile app for Android and iOS);
- Our products and services that are available on or through our websites (including paypal.com, mailchimp.com, bookbaby.com, and amazon.com);
- Other users’ websites that use our services.
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
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Information We Collect
CRLC only collects information about you to provide our Services, to communicate with you, or to make our Services better.
We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Information: We ask for basic information from you when you submit stories to challenges or contests. Emails gathered in this way are only used for communication regarding submissions. This information remains private and will be cleared annually. Stories with bylines and weblinks will be archived publicly at CRLC.
- Public Profile Information: If you have an account with WordPress, Automattic collects the information that you provide for your public profile, including your username, any photo you provided or an “About Me” description. Your public profile information is just that — public — so please keep that in mind when deciding what information to include.
- Transaction and Billing Information: If you buy something from CRLC — a subscription to a newsletter, services, patronage, or a book, for example — you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information through PayPal.com
- Content Information: Depending on the Services you use, you may also provide us with information about you in draft and published content (such as for your website or your Polldaddy survey). For example, if you write a guest blog post that includes biographic information about you, we will have that information, and so will anyone with access to the Internet because we publish the guest posts publicly. This might be obvious to you…but it’s not to everyone!
- Communications with Us (Hi There!): You may also provide us information when you respond to surveys, communicate with Charli Mills, or post in our public comments.
Information We Collect Automatically
Through Automattic’s normal website functions, they also collect some information automatically:
- Log Information: Like most online service providers, Automattic web tools collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. They collect log information when you use our Services — for example, when you submit stories through the WordPress.com form.
- Usage Information: Automattic collects information about your usage of our Services. They use this information to, for example, to provide Services at CRLC, as well as get insights on how people use our Services, so we can make our Services better.
- Location Information: Automattic may determine the approximate location of your device from your IP address. This information calculates how many people visit CRLC from certain geographic regions.
- Interactions with Other Users’ Sites: Automattic collects some information about your interactions with other users’ sites while you are logged in to your WordPress account, such as your “Likes” and the fact that you commented on a particular post. As another example, for Intense Debate users, Automattic collects information about the comments you make while logged in to your account, and use that information to, for example, tally up statistics about your comments (check them out in your WordPress dashboard!) and provide the information about your comments in your Intense Debate public profile.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log into your WordPress.com account through another service (like Google) or if you connect your website or account to a social media service (like Twitter) through our Publicize feature, we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.
We may also get information, such as a mailing address, from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for example, for marketing and advertising purposes like postcards and other mailers advertising our services. (Currently CRLC does not purchase mail list, but in the future, we may expand our readership for collections and books through this type of third-party service.)
How and Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
- To provide our Services and space to practice, share and engage with other writers;
- To further develop and improve our Services;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition;
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of writers at CRLC, other users of Automattic and other blog platforms, which may result in us declining a transaction or the use of our Services;
- To communicate with you, for example through an email, about offers, promotions and events at CRLC we think will be of interest to you, to solicit your feedback, or keep you up to date on CRLC; and
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary to function as a web-based literary community that provides an online platform for you to participate (which is open to those willing); or
(2) The use is necessary for compliance with a legal obligation (CRLC has purchased Automattic products and defers to their legal obligation); or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information — for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our community engagement and promotions, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
How We Share Information
We do not sell our users’ private personal information.
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request. For more information on how we respond to requests for information about WordPress.com users, please see Automattic’s Legal Guidelines.
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Automattic, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so, such as the social media services that you connect to your site through our Publicize feature.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Other Site Owners: If you have a WordPress.com account and leave a comment on a site that uses our Services (like a site created on WordPress.com or a site running Jetpack), your IP address and the email address associated with your WordPress.com account may be shared with the administrator(s) of the site where you left the comment.
- Published Support Requests: And if you send WordPress a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.
Information Shared Publicly
Information that you choose to make public is — you guessed it — disclosed publicly.
When you complete a form to enter your story into a challenge or contest, your story, byline and any link provided will be shared publicly. Your email will not be shared. All copyrights remain with the author.
That also means, of course, that information like your public profile, posts, other content that you make public on our website or yours, and your “Likes” and comments on our website and other websites, are all available to others — and we hope you get a lot of views!
For example, the photo that you upload to your public profile, or a default image if you haven’t uploaded one, is your Globally Recognized Avatar, or Gravatar–get it? :). Your Gravatar, along with other public profile information, will display with the comments and “Likes” that you make on other users’ websites while logged in to your WordPress.com account. Your Gravatar + public profile information may also display with your comments, “Likes,” and other interactions on websites that use our Gravatar service, if the email address associated with your account with us is the same as the email address that you use on the other website.
We also provide a “Firehose” stream of public data (like posts and comments) from sites that use Automattic’s Services to provide that data to Firehose subscribers, who may view and analyze the content (all subject to Automattic’s Terms of Service), but do not have rights to re-publish it, publicly.
Public information may also be indexed by search engines or used by third parties.
Please keep all of this in mind when deciding what you would like to share.
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it — which are described in the section above on How and Why We Use Information — and we are not legally required to continue to keep it.
For example, we keep the web server logs that record information about a visitor to one of Automattic’s websites, such as the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Automattic’s websites and investigate issues if something goes wrong on our website.
As another example, when we delete a post, page, or comment from our WordPress.com site, it stays in our Trash folder for thirty days just in case we would like to restore that content. After the thirty days are up, the deleted content may remain on our backups and caches until purged.
While no online service is 100% secure, we trust the tools and services we’ve purchased from Automattic to work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
To enhance the security of our account, we use WordPress’ advanced security settings, including Two Step Authentication.
You have several choices available when it comes to information about you:
- Limit the Information that You Provide: If you interact with us, you can choose not to provide the optional information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
- Limit Access to Information on Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features.
- Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your participation in contests, anthologies, projects and legal notices.
- Set Your Browser to Reject Cookies: At this time, Automattic does not respond to “do not track” signals across all their Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Automattic’s websites, with the drawback that certain features of Automattic’s websites may not function properly without the aid of cookies.
- Not participate: While we’d be very sad to see you go, if you no longer want to use our Services 🙁 🙁 🙁 :(, you can choose to not participate. Please keep in mind that we may continue to retain your information from previous participation, as described in How Long We Keep Information above.
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You can usually access, correct, or delete your personal data using your Gravatar account settings and tools you use through Automattic, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.
In addition, if you want to request a correction or deletion to a comment or story you published, contact CRLC.
EU individuals also have the right to make a complaint to a government supervisory authority.
Controllers and Responsible Companies for Automattic
Automattic’s Services are worldwide. Different Automattic companies are the controller (or co-controller) of personal information, which means that they are the company responsible for processing that information, based on the particular service and the location of the individual using our Services.
Depending on the Automattic Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is the Automattic company that entered into the contract with you under the Terms of Service for the product or service you use. In addition, Automattic Inc., our US-based company, is the controller for some of the processing activities across all of our Services worldwide.
The chart below explains the controllers for processing your personal information. We use the term “Designated Countries” to refer to Australia, Canada, Japan, Mexico, New Zealand, and all countries located in the European continent.
|If you reside outside of the Designated Countries (for services other than those offered at WooCommerce.com):||Automattic Inc.
60 29th Street #343
San Francisco, CA 94110
|If you reside in the Designated Countries (for services other than those offered at WooCommerce.com):||Aut O’Mattic A8C Ireland Ltd.
Business Centre, No.1 Lower Mayor Street
International Financial Services Centre
Dublin 1, IrelandAutomattic Inc. is also the controller for some of the processing activities related to Services provided by Aut O’Mattic A8C Ireland Ltd.
|If you are using our Services offered at WooCommerce.com:||Bubblestorm Management (Pty) Ltd (WooCommerce.com)
Unit A206, The Old Biscuit Mill (TOBM)
373 – 375 Albert Road, Woodstock
Cape Town, South AfricaAutomattic Inc. is also the controller for some of the processing activities related to Services provided by Bubblestorm Management (Pty) Ltd (WooCommerce.com).
How to Reach Us
Other Things You Should Know (Keep Reading!)
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask Automattic (contact listed above) for more information about the steps they take to protect your personal information when transferring it from the EU.
Ads and Analytics Services Provided by Others
CRLC does not allow third-party ads through AdWords or Amazon. Any ads for promotions, events, books or services belong to CRLC. No data is collected beyond what is described here as part of Automattic’s tools to run a website.
Third Party Software
At this time CRLC does not use third-party software, such as Woocommerce.com.
Visitors to Our Users’ Websites
CRLC uses any data collected by Automattic’s tools for the purpose of operating a literary community, providing engagement between readers and writers, and communicating with participants. Insights help gauge the success of the site and private information collected by CRLC is never shared or sold. If you’d like, you can also read more about the data Automattic collects on our behalf in their Privacy Notice.
That’s it! Thanks for reading. And thanks to Automattic for providing the necessary language to be adapted to CRLC and for clearly explain their practices to uses and our visitors.
- May 25, 2018: Created policy to provide more specific information to clarify our practices and reflect the requirements of the EU’s General Data Protection Regulation.