Draft of May 28, 2020

Privacy Policy

Last updated May 2020 

Privacy Policy Consent

The website and its content is owned by Vesta Divorce, Inc. (“Company”, “we”, or “us”). 

The term “you” refers to the user or viewer of http://www.vestadivorce.com (“Website”).

This Privacy Policy describes how we collect, use, process and distribute your information, including Personal Data (as defined below) used to access this Website. We will not use or share your information with anyone except as described in this Privacy Policy. The use of information collected through our Website shall be limited to the purposes under this Privacy Policy and our Terms of Use for customers.

Please read this Privacy Policy carefully. We reserve the right to change this Privacy Policy on the Website at any time without notice. In the event of a material change, we will let you know via email and/or a prominent notice on our Website.

Use of any personal information or contribution that you provide to us, or which is collected by us on or through our Website or its content is governed by this Privacy Policy. By using our Website or its content, you consent to this Privacy Policy, whether or not you have read it.

Information We May Collect

Personal Information. We collect personal information from you so that we can provide you with a positive experience when utilizing our Website or content. We will only collect the minimum amount of information necessary for us to fulfill our obligation to you. We, or any third-party payment processor we use, may collect:

1. A name and an email address so we can deliver our newsletter to you – you would be affirmatively consenting to this by providing this to us in our contact forms.
2. A name, an email address and other contact information if you request to be connected with a Vetted Vesta Professional.
3. If we provide products or services for a fee, billing information including name, address, email address and credit card information so that we can process payment to deliver our products or services to you under a contractual obligation to do so.
4. A name and an email address if you complete our contact form with a question. We may send you marketing emails with either your consent or if we believe we have a legitimate interest to contact you based on your contact or question.

Please note that the information above (“Personal Data”) that you are giving to us is voluntarily, and by you providing this information to us you are giving consent for us to use, collect and process this Personal Data. You are welcome to opt-out or request for us to delete your Personal Data at any point by contacting us at team@vestadivorce.com 

If you choose not to provide us with certain Personal Data, you may not be able to participate in certain aspects of our Website or content.

Anonymous Data Collection and Use. To maintain our Website’s high quality, we may use your IP address to help diagnose problems with our server and to administer the Website by identifying which areas of the Website are most heavily used, and to display content according to your preferences. Your IP address is the number assigned to computers connected to the Internet. This is essentially “traffic data” which cannot personally identify you, but is helpful to us for marketing purposes and for improving our services. Traffic data collection does not follow a user’s activities on any other websites in any way. Anonymous traffic data may also be shared with business partners and advertisers on an aggregate basis.

Use of “Cookies.” We may use the standard “cookies” feature of major web browsers. We do not set any personally identifiable information in cookies, nor do we employ any data-capture mechanisms on our Website other than cookies. You may choose to disable cookies or have your browser notify you when you receive a new cookie through your own web browser’s settings. However, disabling this function may diminish your experience on our Website and some features may not work as intended. For instance, if you block or otherwise reject our cookies, you will not be able to add items to your Shopping Cart, proceed to checkout, or use any our products and services that require you to sign in.

What We Do With Information We Collect

Confidentiality. We aim to keep the Personal Data that you share with us confidential except as set forth below.

Contact You. We may contact you with information that you provide to us based on these lawful grounds for processing:

1. Consent. We may contact you if you give us your clear, unambiguous, affirmative consent to contact you.
2. Contract. If we offer products or services for a fee, we will contact you under our contractual obligation to deliver any products or services you purchase from us.
3. Legitimate Interest. We may contact you if we otherwise feel you have a legitimate interest in hearing from us, like communication about seminars.

You will always have the option to opt out of any of our emails.

Process Payments. If we offer products or services for a fee and you purchase any of the foregoing from us, we will use the Personal Data you give to us in order to process your payment under the contract for sale. We intend to use only use third party payment processors that take the utmost care in securing data and comply with the GDPR.  At this time, we do not collect credit card information directly.

Provide Contact Information to Vetted Vesta Professionals.  We may provide your contact information to Vetted Vesta Professionals if you so request and provide clear, unambiguous, affirmative consent to our doing so.

Protection of Us and Others. We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of us, our customers or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Obviously, however, this does not include selling, renting, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

Business Transfers. In the event that the Company or substantially all of its assets are acquired, customer information will of course be one of the transferred assets.

Viewing by Others. Note that whenever you voluntarily make your Personal Data available for viewing by others online through this Website or its content, it may be seen, collected and used by others, and therefore, we cannot be responsible for any unauthorized or improper use of the information that you voluntarily share (i.e., sharing a comment on a blog post, posting in a Facebook group that we manage, etc.).

Submission, Storage, Sharing and Transferring of Personal Data. Personal Data that you provide to us is stored internally or through a data management system. Your Personal Data will only be accessed by those who help to obtain, manage or store that information, or who have a legitimate need to know such Personal Data (i.e., our hosting provider, newsletter provider, payment processors or team members).

It is important to note that we may transfer data internationally. For users in the European Union, please be aware that we transfer Personal Data outside of the European Union. By using our Website and providing us with your Personal Data, you consent to these transfers in accordance with this Privacy Policy.

With Your Consent. Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.

Data Retention

We retain your Personal Data for the minimum amount of time necessary to provide you with the information and / or services that you requested from us. We may include certain Personal Data for longer periods of time if necessary for legal, contractual and accounting obligations.

Passwords

To use certain features of the Website or its content, you may from time to time need a username and password. You are responsible for maintaining the confidentiality of the username and password, and you are responsible for all activities, whether by you or by others, that occur under your username or password and within your account. We cannot and will not be liable for any loss or damage arising from your failure to protect your username, password or account information. If you share your username or password with others, they may be able to obtain access to your Personal Data at your own risk.

You agree to notify us immediately of any unauthorized or improper use of your username or password or any other breach of security. To help protect against unauthorized or improper use, make sure that you log out at the end of each session requiring your username and password.

We will use our best efforts to keep your username and password(s) private and will not otherwise share your password(s) without your consent, except as necessary when the law requires it or in the good faith belief that such action is necessary, particularly when disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.

How You Can Access, Update or Delete Your Personal Data

You have the right to:

1. Request information about how your Personal Data is being used and request a copy of what Personal Data we use.
2. Restrict processing if you think the Personal Data is not accurate, unlawful, or no longer needed.
3. Rectify or erase Personal Data and receive confirmation of the rectification or erasure. (You have the “right to be forgotten”).
4. Withdraw your consent at any time to the processing of your Personal Data.
5. Lodge a complaint with a supervisory authority if you feel we are using your Personal Data unlawfully.
6. Receive Personal Data portability and transference to another controller without our hinderance.
7. Object to our use of your Personal Data.
8. Not be subject to an automated decision based solely on automatic processing, including profiling, which legally or significantly affects you.

Unsubscribe. You may unsubscribe from our e-newsletters or updates at any time through the unsubscribe link at the footer of all email communications. If you have questions or are experiencing problems unsubscribing, please contact us at team@vestadivorce.com.

Security and Other Policies

Security. We take commercially reasonable steps to protect the Personal Data you provide to us from misuse, disclosure or unauthorized access. We only share your Personal Data with trusted third parties who use the same level of care in processing your Personal Data. That being said, we cannot guarantee that your Personal Data will always be secure due to technology or security breaches. Should there be a data breach of which we are aware, we will inform you immediately.

Anti-Spam Policy. We have a firm no spam policy and provide you with the ability to opt-out of our communications by selecting the unsubscribe link at the footer of all e-mails. We have taken the necessary steps to ensure that we are compliant with the CAN-SPAM Act of 2003 by never sending out misleading information. We will not sell, rent or share any email address obtained from our website.

Third Party Websites. This Site may periodically provide links to third-party Web sites (“Third-Party Sites”). This Agreement governs only this Site and not any Third-Party Sites. Our decision to link to a Third-Party Site is not an endorsement of the content or services in that linked Third-Party Site. We do not control these Third-Party Sites and expressly disclaim any responsibility for the content, the accuracy of the information and any products or services available on the Third-Party Sites. If you decide to access linked Third-Party Sites, you do so at your own risk. You should direct any concerns regarding any Third-Party Sites to the administrator of the applicable Third-Party Site. You should also refer to the separate terms of use, privacy policies and other rules posted on Third-Party Sites before you use them to understand, among other things, how they respectively store, use and protect the privacy of your Personal Data.

Children’s Online Privacy Protection Act Compliance. We do not collect any information from anyone under 18 years of age in compliance with COPPA (Children’s Online Privacy Protection Act) and the GDPR (General Data Protection Regulation of the EU). Our Website and its content are directed to individuals who are at least 18 years old or older.  If you are under the age of 18, please do not provide personal information of any kind whatsoever. If a child provides us with personally identifiable information, a parent or guardian of that child may contact us if they would like this information deleted from our records.

Notification of Changes. We may use your Personal Data, such as your contact information, to inform you of changes to the Website or its content, or, if requested, to send you additional information about us. We reserve the right, at our sole discretion, to change, modify or otherwise alter our Website, its content and this Privacy Policy at any time. Such changes and/or modifications shall become effective immediately upon posting our updated Privacy Policy. Please review this Privacy Policy periodically. Continued use of any of information obtained through or on the Website or its content following the posting of changes and/or modifications constituted acceptance of the revised Privacy Policy. Should there be a material change to our Privacy Policy, we will contact you via email or by a prominent note on our Website.

Data Controller and Processors. We are the data controllers as we are collecting and using your Personal Data. We use trusted third parties as our data processors for technical and organizational purposes, including for payments and email marketing. We use reasonable efforts to make sure our data processors are GDPR- compliant.

California Residents

California Consumer Privacy Act

If you are a California resident, the information below also applies to you. Certain terms used in this section have the meanings given to them in the California Consumer Privacy Act of 2018 (“CCPA”). 

Categories of Personal Information we have collected from or about persons visiting our website in the preceding 12 months

• Identifiers (e.g. name, mailing address, email address, phone number, credit/debit card number) 
• Characteristics of protected classifications (e.g. gender, age) 
• Commercial information (e.g. products or services purchased, purchase history) 
• Internet or other electronic network activity (e.g. browse or search history) 
• Geolocation data (e.g. latitude or longitude) 
• Inferences drawn from any of the above (e.g. preferences or characteristics) 

Business or Commercial purposes for which the Company has collected Personal Information about website visitors in the preceding 12 months (for more information, see the What We Do With Information We Collect section of this privacy policy). 

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services; 
• Auditing related to a current interaction with you and concurrent transactions; 
• Short-term, transient use, including, but not limited to, use as part of the same interaction in which information is collected; 
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; 
• Debugging to identify and repair errors that impair existing intended functionality; 
• Undertaking internal research for technological development and demonstration; and 
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us. 

Categories of Personal Information the Company has disclosed for a business purpose in the preceding 12 months

• Identifiers (e.g. name, mailing address, email address, phone number, credit/debit card number) 
• Characteristics of protected classifications (e.g. gender, age) 
• Commercial information (e.g. presentations attended) 
• Internet or other electronic network activity (e.g. browse or search history)

Non-Discrimination

The Company will not discriminate against you because you exercise your rights. For example, the Company will not deny you goods or services or charge you a different price or rate for goods or services if you make an access or deletion request. 

You have the following rights under the CCPA –

The right to make requests as follows: 

Access Request (can make a request no more than twice in a 12-month period) – Request that the Company disclose the following information

– Categories of personal information (“PI”) we collected about you during the preceding 12 months 

– Categories of sources from which PI is collected 

– Business or commercial purpose for collecting or selling PI 

– Specific pieces of PI we collected about you 

– Categories of PI Target has sold about you (note that we do not sell PI)

– Categories of third parties to whom the PI was sold 

– Categories of PI disclosed about you for a business purpose 

– Categories of third parties to whom PI was disclosed for a business purpose 

Deletion Request

– Request that the Company delete PI that we collected from you 

To submit an Access Request or Deletion Request, please submit your request to Vesta Divorce, Inc., 180 Wells Ave., Suite 300, Newton, MA 02459, Attn:  Website Team.

California Shine the Light

If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to Vesta Divorce, Inc., 180 Wells Ave., Suite 300, Newton, MA 02459, Attn: Website Team/California Shine the Light Inquiry. Please allow 30 days for a response. 

If you are a California resident under 18 years old and a registered user, you can request that we remove content or information that you have posted to our website or other online services. Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please submit your request to Vesta Divorce, Inc., 180 Wells Ave., Suite 300, Newton, MA 02459, Attn:  Website Team.

If You Have Questions

If you have any questions about this Privacy Policy, please contact us at:

Vesta Divorce, Inc.

180 Wells Ave., Suite 300

Newton, MA 02459

United States

Attn: Website Team

Email: team@vestadivorce.com