Privacy and Cookie Policy

Thank you for your interest in my Privacy Policy. This Privacy Policy applies to my website, www.ellabraeme.com operated by me, Ella Braeme,103 W General Screven Way Ste G PMB 1036, Hinesville, GA 31313 United States, acting as the data controller, and the third parties I’m using to provide the website (“we”, “us”, “our”). If you have any questions, please contact me using ella@ellabraeme.com, or write to me at the above address.

BACKGROUND

This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective I would like to explain to you the following three concepts.

What is Personal Data?

Personal Data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.

What is Processing?

“Processing” means and covers virtually any handling of data.

What law applies?

I act as the data controller in accordance with Germany’s Data Protection Act (Bundesdatenschutzgesetz) (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”).

GENERAL PRINCIPLES

Purpose and legal basis of processing

In accordance with the DPA and GDPR we need to have both a purpose and a legal basis to process Personal Data. The purposes are:

providing the website and its functions and contents,
responding to contact requests and communicating with my clients, followers and website users,
providing my coaching services, and
security measures.

Of course, we can only do that if we have at least one of the following legal bases or in other words lawful reasons to do so. Unless specifically described below, we typically link the above purposes to one of the following:

consent,
to fulfill our services and carry out contractual obligations,
to fulfill our legal obligations, and
to protect our legitimate interests.

Security

We take appropriate organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we collect and process. However, no method of collection, storage, or transmission is 100% secure. You are solely responsible for limiting access to your devices, and signing out of websites after your sessions.

Retention and Storage

I retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy and in particular, for the duration of our business relationship and statutory retention periods in accordance with Germany’s Commercial Law (HGB) and Fiscal Code (AO), among others. The retention and documentation periods specified vary between two to ten years.

Minors

I do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

Automated decision-making

Automated decision-making including profiling does not take place.

Do Not Sell

I do not sell your Personal Data.

Special Category Data

Unless specifically required for a particular service and consent is obtained, I do not process special category data.

International Transfer

In the course of my website operation, we process data. We usually do not transfer Personal Data to countries outside Germany and the EEA. However, if we do, I will make sure that processing of your Personal Data is governed by Data Processing Agreements that include Standard Contractual Clauses for a high level of data protection.

Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of my services, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings at home or abroad or to fulfill our legitimate interests.

Marketing

If you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

Direct Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. The legal basis for processing is the initiation of a contract, our legitimate interest and your consent.

DATA COLLECTION AND PROCESSING

a) Personal Data that you give us:

This is information about you that you give to us by filling in forms on my website (or other forms that we ask you to complete), or when you correspond with me. It may include, for example, your name, address, email address and telephone number; information about your business relationship with me; and information about your requirements, background and interests.

If you are interested in buying my ebooks you will be redirected to Books2Read (Draft2Digitial LLC, 812 Old Bugle Rd Edmond, OK, 73003-6263 USA) or Amazon.com, Inc (Amazon Web Services, Inc.,410 Terry Avenue North Seattle, WA 98109 United States), as applicable, and as such your IP address and other data may be transferred to the relevant service operator. We have no influence or control over the data collected and processed by the relevant service operator when you are being redirected and you can learn more about their data processing in the relevant service operator’s privacy Notice. We use the services of the relevant service operator on the basis of our legitimate interests in conjunction with the initiation of a (pre)contractual relationship with you.

When you go ahead and read the reading sample of “So Many Steps” in your browser, you are redirected to Bookfunnel LLC (5205 W. Broadway St. 184, Pearland, Texas 77581) and Bookfunnel logs your IP address for documentation purposes. This is a mere technical process and required to make the reading sample of “So Many Steps” available for download to your device or depending on your browser available for viewing. We use the services of Bookfunnel LLC on the basis of our legitimate interests in conjunction with the initiation of a (pre)contractual relationship with you. If you register during the download process for my mailing list, we may send you the occasional email for marketing purposes. The only data required for our mailing list is your name and email address. The processing bases are your consent and our legitimate interest.

We use your data (name and email address) provided by you when you subscribe to my newsletter within the legally permissible scope for marketing purposes using the services of MailerLite (548 Market St, PMB 98174, San Francisco, CA 94104-5401, United States). You can unsubscribe at any time via the link provided for this purpose in each email we send or by sending us an informal message. After unsubscribing, your email address will be deleted immediately.

Within the reader’s blog you may be able to display certain profile information, share certain details, engage with others, exchange knowledge and insights, post and view relevant content. It’s your choice whether to include sensitive information in your comment and to make that sensitive information public. Please do not post or add Personal Data to your comment that you would not want to be available. The processing bases are your consent as well as our legitimate interest.

You may also participate in my raffles and if you do so, we usually process your name, email address and the answer to the prize question (If any). We use this information to notify you if you win and to request further information. The legal basis for data processing is contract. To carry out my raffles we use depending on the specific raffle the following service providers: KingSumo (Sumo Group Inc. 1305 E. 6th St #3 Austin, TX 78702 USA), BookSweeps (96 Mowat Ave M6K 3M1 Toronto Ontario, Canada) and Rafflecopter (Metric Feat, LLC of 613 Pine St, Unit 3, Boulder, CO, 80302, USA).

Finally, I process some of your data in the context of administrative tasks as well as organization of my business, and compliance with legal obligations, such as archiving. In this regard, I process the same data that I process in the course of providing my contractual services. The processing bases are my legal obligations and my legitimate interest.

b) Personal Data that my website and other systems collect about you:

If you visit my website it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website.

We use so-called cookies on my website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in Germany`s Act on Data Protection and the Protection of Privacy in Telecommunications and Digital Services (Gesetz über den Datenschutz und den Schutz der Privatsphäre in der Telekommunikation und bei digitalen Diensten) (“TDDDG”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to myCookie Policy.

My website uses the cookie consent tool “Real Cookie Banner: GDPR & ePrivacy Cookie Consent”

By devowl.io GmbH (Tannet 12, 94539 Grafling, Germany) to obtain your consent to the storage of cookies and to document this consent. When you enter my website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to my website.

c) Other information:

We may also process aggregated data such as statistical or demographic data for any purpose including improving my website and services. Aggregated data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. Direct Marketing generally takes the form of email using the service provider MailerLite but may also include other less traditional or emerging channels. These forms of contact will be managed by me, or by my contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

DATA PROCESSING THROUGH THIRD-PARTY SERVICES

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”). This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any: a) Hosting and Content Management System: WordPress, a service provided by Automattic Inc; b) Analytics: Google Analytics by Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, US, and Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland); c) Fonts: Google Fonts by Google ;

SOCIAL MEDIA

I’m present on social media on the basis of my legitimate interest (currently Facebook, Instagram and Threads (Meta Platforms, Inc., 1601 Willow Road Menlo Park California 94025 and 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland), YouTube (Google), MeWe (Sgrouples, Inc, 85 Paul Avenue Mountain View CA 9404, USA), Vero (VERO Labs, Inc, 101 W 23rd St, Suite 2394,

New York, NY, 10011, USA). If you contact or connect with me via social media, the relevant social media platform and I are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Information from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

YOUR RIGHTS AND PRIVILEGES

Privacy Rights

You can exercise the following rights:

Right to information
Right to rectification
Right to object to processing
Right to deletion
Right to data portability
Right to withdraw consent
Right to complain to a supervisory authority
Right not to be subject to a decision based solely on automated processing

If you have any questions, please contact us.

Updating your information and withdrawing your consent

If you believe that the information I hold about you is inaccurate or request its rectification, deletion, withdrawal of consent or object to its processing, please do so by contacting me.

Access Request

In the event you want to make a Data Subject Access Request, please contact us. I will respond to requests regarding access and correction as soon as reasonably possible. Should I not be able to respond to your request within thirty (30) days, I will tell you why and when I will be able to respond to your request. If I`m unable to provide you with any Personal Data or to make a correction requested by you, I will tell you why.

Complaint to a supervisory authority

You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data. The supervisory authority at federal level is the Federal Commissioner for Data Protection and Freedom of Information (“BfDI”) (www.bfdi.bund.de) is the Federal Commissioner for Data Protection. The data protection authority in Schleswig-Holstein is the state Data Protection Authority (“ULD”) (www.datenschutz-berlin.de). However, I would be pleased if we can resolve your concerns before you contact the BfDI or the ULD.

HELP AND COMPLAINTS

If you have any questions about this policy or the information we hold about you please contact me using ella@ellabraeme.com or write to me at the above address.

CHANGES

The first version of this policy was issued on Saturday 27th of July 2024 and is the current version. Any prior versions are invalid and if we make changes to this policy, we will revise the effective date.

Cookie Policy

This Cookie Policy applies to www.ellabraeme.com operated by me, Ella Braeme103 W General Screven Way Ste G PMB 1036, Hinesville, GA 31313 United States (“we”, “us”, or “our”).

This policy sits in line with Germany`s Act on Data Protection and the Protection of Privacy in Telecommunications and Digital Services (Gesetz über den Datenschutz und den Schutz der Privatsphäre in der Telekommunikation und bei digitalen Diensten) (“TDDDG”) and the EU`s counterpart the Privacy and Electronic Communications Directive (“PECD”).

For more information about how we protect your personal data, please see my Privacy Policy. If you have any questions, please contact me using ella@ellabraeme.com or write to me at the above address.

WHAT IS A COOKIE?

Cookies are text files containing small amounts of information which are downloaded to your device (e.g. computer, smartphone, electronic device which accesses the internet) when you visit a website. Cookies can be useful because they allow a website to recognise a user’s device, preferences and generally help to improve your online experience.

WHAT TYPES OF COOKIES DO WE USE AND HOW LONG DO THEY LAST?

There are three types of cookies that we use, Necessary Cookies, Analytics Cookies and Marketing Cookies. These cookies perform different functions as explained below above the relevant cookies sections.

Necessary Cookies

Necessary cookies are essential in order to provide you with the services you request on our website and in order that we can comply with legal obligations. We do not need to ask for your consent in order to use these cookies as without them we would not be able to provide the services requested by you. These are always active on the Website.

Analytics Cookies

Analytics cookies collect information about things like how many people visit our Website, what parts of the Website people look at and how many new visitors we have to the Website. These cookies help us to monitor how effective our Website is and to improve it, tailoring it to our visitors. Analytics cookies are only used if you consent to it in our Cookie Consent Tool.

Marketing/Advertising Cookies

Marketing cookies help us provide you with personalized and relevant services or advertising, and track the effectiveness of our digital marketing activities. They are capable of tracking your browser across other websites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. Advertising cookies are only used if you consent to it in the Cookie Consent Tool.

CONSENT

Necessary Cookies will always be active on your device, but we ask for your consent to place Analytics and Advertising Cookies and other similar technologies on your device. If at any time you want to change your cookie settings, including withdrawing your consent to this processing, we would encourage you to do this via the links below. You may need to refresh the page before the changes to the settings take effect.

THE COOKIES WE USE

Google Analytics

We use Google Analytics, a web analysis service of Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, US, and Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland). Google Analytics uses a specific form of cookie, which is stored on your device and enables an analysis of your use of our website. The cookies set by Google Analytics for measurement are different for each visitor (i.e. there is not a single Google Analytics cookie ID that is used on all sites using Google Analytics). The information about your use of our website generated by the cookie is generally transmitted to a Google server in the USA and stored there.

Google uses this information on our behalf to analyze your use of this website in order to compile reports on website activities and provide additional services related to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other data. In the configuration of Google Analytics, we ensured that Google receives this data as a processor and is therefore not allowed to use this data for its own purposes.

In relation to the data transfer into the USA Google’s processing agreement for Google Analytics, can be read here. You can disable tracking by Google Analytics with future effect by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser following this link.

Facebook Pixel

We also use the “Facebook pixels” of the social network Facebook (Meta Platforms, Inc., 1601 Willow Road Menlo Park California 94025 and 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland). With the help of the Facebook pixel, it is possible for Facebook to determine the visitors to our offer as a target group for the display of advertisements, so-called “Facebook ads”. Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our website. This means that with the help of the Facebook pixel we want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad. You can object to the collection by the Facebook pixel and use of your data for the display of Facebook ads. To do so, you can visit the page set up by Facebook and follow the instructions here.

HOW TO BLOCK COOKIES AND THE CONSEQUENCES OF THIS

If you want to block all cookies, you may be able to do this through the settings in your browser for each browser you use and each device you use to access the internet (Google Chrome, Mozilla Firefox, Microsoft Edge, Opera, Safari).

We also offer a Cookie Consent Tool when you first visit our website. This tool allows you to specify your preference about cookies. You can accept or reject them or access this Cookie Policy before giving your consent to cookies or rejecting them. This permits you to make an informed decision about the cookies we use. You are free to accept or reject cookies, but note that after rejecting them, browsing our website might be less user-friendly and the relevant content might be affected.

In addition, if you do not wish to participate in advertising personalisation or retargeting/tracking you can object to behavioural advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices the European Interactive Digital Advertising Alliance (Europe only), and Google Ad Settings,

HELP AND COMPLAINTS

If you have any questions about this policy or the information we hold about you please contact me using ella@ellabraeme.com or write to me at the above address.

CHANGES