Welcome to Jeffrey A. Sheehan’s Website, www.website.com (the “Website” or “Platform”).  The Platform is operated by By Jeffrey A. Sheehan Works LLC (“we,” “us,” or “our”).  We believe that the privacy and security of your information and data (“Information”) are very important.  This Privacy Policy (“Policy”) explains the type of information we collect from users of the Platform, how that information is used, how the Information may be shared with other parties, and what controls our users have regarding their Information. We encourage you to read this Policy carefully. 

Any updates or modifications to this Policy will be posted to our Website on this page. By using or accessing the Platform, you signify that you have read, understand, and agree to be bound by this Policy.  This Policy is effective as of 11 November 2019 and has not been modified since that date.

Our Platform is operated in the United States but can be accessed worldwide. Residents of the European Economic Area (“EEA”), which includes the member states of the European Union, should consult the sections of this policy relating to the “Rights of EEA Residents” (under the “Your Rights” section below) and “International Data Transfers” for provisions that may apply to them.

Information We Collect and How We Use It

• Types of Information

We may collect the following types of Information through our Platform:

(1) “Personal Data” such as your name, e-mail address and phone number and other information that can be used to directly identify you (which, in some cases, may include certain Device Information);

(2) “Device Information” which is information relating to the computer or device you are using when you access our Platform, such as your computer’s IP address, your mobile device identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, and your device and browser settings.

(3) “Usage Data” which is data related to your use of the Platform such as the pages you visit, the sites you use before or after visiting ours, your actions within the Platform, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, WiFi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.

As described in more detail below, we collect Personal Data only when you provide it to us but may collect other types of Information whenever you use our Platform through automated means such as software developer kits, cookies and web beacons (which are discussed in more detail below).

• Personal Data

You may enter the Websites and browse their content without submitting any Personal Data.  However, we will need to collect relevant Personal Data to provide you with certain services offered by the Platform, including if you choose to contact us or otherwise communicate with us in any way, subscribe or opt in to our newsletter, alerts, or other communications, or participate in a contest or promotion.

We use the Personal Data that we collect to respond to your requests, communicate with you regarding the Platform and our content, send you promotional e-mails, guard against potential fraud, and provide you with the applicable services, features or functionality associated with your submission.  When you submit Personal Data through the Platform, whether by directly providing it to us upon request or voluntarily disclosing it through comments, you are giving your consent to the collection, use and disclosure of your Personal Data as set forth in this Privacy Policy.

• Device Information & Usage Data

Whether or not you submit Personal Data, any time you visit our Platform, we or our service providers may collect, store or accumulate certain Device Information and Usage Data. This Information may be used in furtherance of the purposes described above with respect to Personal Data and in aggregate form for internal business purposes, such as optimizing the Platform, evaluating the popularity of content, generating statistics and developing marketing plans, and otherwise for general administrative, analytical, research, optimization, and security purposes.

• Information to and from Social Networks

We may provide functionality that will allow you to connect to our Platform through a third-party social network such as Facebook, Twitter or Instagram (each, a “Social Network”). If you connect through a Social Network, we may collect Personal Data from your profile, such as your name, username, and e-mail address, and we will use that Personal Data for the purposes set forth herein. In addition, our Platform may offer social sharing features which will allow you to “Share” or “Like” on a Social Network. If you decide to use such features, it may allow the sharing and collection of Information both to and from such Social Network so you should check the privacy policy of each Social Network before using such features.

Sharing of Information

In no event will we disclose, rent, sell or share any of your Personal Data to third parties for direct marketing purposes. We only share your Information with third parties for the purposes described below.

We contract with companies or individuals to provide certain services related to the functionality and features of the Platform, including content streaming, email and hosting services, software development, data management, management of quizzes and polls, marketing, and administration of contests and other promotions. We call them our “Service Providers.” We may share your Information with Service Providers as appropriate for them to perform their services for us and our Service Providers are permitted to use your Information only for such purposes. 

We may also share or transfer Device Information and Usage Data in aggregated, anonymized form with or to our affiliates, licensees, partners and Service Providers for administrative, analytical, research, optimization, and security purposes, but no such Information will be linked with your Personal Data or be used to identify or contact you.

Finally, we may share your Information: (i) In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us; (ii) When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms of Use and other agreements.

Notwithstanding any of the above, we will not share your Personal Data if such sharing is prohibited by applicable privacy and data protection law, including, without limitation, the EEA’s General Data Protection Regulation effective May 25, 2018.