Privacy Policy – Innerlair

Last updated: July 22, 2020

At Innerlair (“Innerlair”, “we”, “us”, or “our”) we care deeply about protecting your privacy. We are providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of your personal information that we receive through our website located at https://innerlair.com (the “Website”). We operate the Website, a digital reading platform that enables users to acquire and read or listen to written works (through ebooks, audiobooks or podcasts) using a variety of electronic devices, software applications, and other services (collectively, the “Services”). This Privacy Policy explains how we collect, use, and disclose Personal Information (as defined below) about you gathered during your use of the Services.

The Services offer a wide variety of content. However, not all of Innerlair’s sources of content may be relied upon to provide accurate, complete or current information. Some of the content may even be viewed as offensive, inaccurate, or controversial. You are responsible for your own use of Services, and parents and guardians are responsible for their children’s use of and access to content available on the internet or otherwise via the Services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT WILL HELP YOU MAKE INFORMED DECISIONS ABOUT SHARING YOUR PERSONAL INFORMATION WITH US..

Personal Information

“Personal Information” is any information or a combination of pieces of information that can reasonably permit you to be identified, or that can reasonably be linked to you. Information that is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person is not Personal Information and may be used for any business purpose.

Collection of Personal Information

We collect Personal Information about you from a variety of sources. We collect information from you directly (e.g., when you contact us or create an account with us), automatically, (e.g., data collected via cookies and similar technologies when you use the Services), and from other sources, including commercially available sources, such as public databases (where permitted by law).

1. Information you provide to us

Account Information: When you sign up for our Services, we ask you for information such as name, email address, phone number, payment information or other information. This information is necessary for us to provide you the Services. If you do not provide this information we would not be able to provide the Services to you.
Communicating with us: When you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services, you provide us with Personal Information such as your name and email address. Please note that information you provide to us through feedback, surveys, suggestions, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and any other unsolicited submissions without the parts that identify you, will be treated as non-confidential and non-proprietary and we may use it and share it with third parties.
Information we collect from your use of the Services

We collect Personal Information when you use or otherwise interact with the Services. For example, we collect information about how you use the Services, such as pages you view, the rate at which you consume e-content (how often and for how long), genres, authors or subject matter you prefer and searches you make or share, the ebooks or audiobooks you have liked, comments you have left and also websites you have viewed through links in the comments. We collect this information across the various devices, applications, and other tools through which you access and interact with the Services.

2. Information we automatically collect about you

Whenever you visit or interact with the Services, Innerlair, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about your online activity.

For information about our use of cookies and other similar technologies, you can read our Cookie Policy here. In addition, please note that we automatically collect the following information about you:

Device Information: We may automatically collect your IP address or other unique identifier for the computer, mobile device, tablet or other device you use to access the Services, including the hardware model and mobile network information. The data may be used to help diagnose problems with our servers, analyse trends, track users’ web page, email and mobile application movements/activities, help identify or gather broad demographic information for aggregate use, modeling and to retarget online and to serve interest based or other advertisements to you across computers or devices you may use.
Location Information: We collect general information about where traffic and purchases on our Website are coming from around the world. This is used at an aggregate level (that does not identify individual users) to create reports to better understand our engagement with users.
Third Party Service Providers: We may use third party service providers to support the Services. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, or other technologies to receive, collect, and store information on our behalf.
Third Party Analytic Technologies: We may use third parties’ analytics and tracking tools, such as Google Analytics, Adobe Marketing Cloud, Facebook Custom Audience and others, to help us track, segment and analyse usage of the Services, and to help us or those third parties serve more targeted advertising to you on the Services and across the internet.
Embedded content from other websites: Articles on the Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

3. Information we collect from other sources.

We may receive additional information about you from third party service providers, such as demographic data, your activities on and off the Services through partnerships and our third-party advertisers. We may supplement the information we collect with information received from data suppliers and commercially available resources (e.g. demographic information and additional contact information).

How and Why We Use the Information We Collect

We will use and process your Personal Information lawfully, fairly and in a transparent manner. We will collect and use your Personal Information solely for the specified and legitimate purposes stated in this Privacy Policy. Except as otherwise stated, we may use your information to improve the content of our Services, to customize the Services to your preferences, to communicate information to you (if you have requested it), for our marketing and research purposes, for the fulfillment of services and related activities, and account management. We may use your Personal Information for the following purposes:

Identification and authentication: We use your information to verify your identity when you access your account and to ensure the security of your Personal Information;
Operating the Services: We process your Personal Information to provide you with access to the Services and to process your transactions, as you have requested. We use Personal Information, such as your location to identify whether content is available in your region. We also use information to provide and improve the Services, identify and troubleshoot errors, and analyze the Services;
Managing your account: We use Personal Information to create, maintain, and monitor your account.
Improving the Services: We analyze information about how you use the Services to provide an improved experience for all users;
Communicating with you: We may use your Personal Information to communicate with you, for example if we are providing information about changes to the terms and conditions, to issue security alerts or reminders, or if you contact us with questions. You’re able to email us using the contact us page. This gives you the option to send an email from any of your email accounts to us. We will do our best to keep this email private, secure and to reply as soon as possible. By just emailing us you will NOT be added to any mailing list or marketing list. If you do wish to be added to our mailing list you are able to give consent and opt in using one of the forms on this Website;
Marketing: We may use your Personal Information to learn about the interests of the users, to build a profile about you and place you into particular marketing segments, and to identify the devices you use to access digital content and the Services in order to better understand your preferences and to appropriately personalize the marketing messages we send to you. We may also use your identifiers to send you marketing communications about the Services and other products or services that may be of interest to you, subject to any consent that may be required under applicable law. This may include information regarding services and offers associated with our affiliates. We will not require you to consent to receive marketing as a condition of receiving the Services, and you may withdraw any consent you have provided at any time;
Personalized Advertising and Re-marketing: We use Personal Information to: (i) serve you with targeted advertising that may interest you based on your device activity and inferred interests (ii) measure the effectiveness of targeted advertising, and (iii) understand the usage of our Services. Our third party advertisers may use Personal Information (such as cookies, platform device identifiers, software agents, and IP address), to deliver targeted advertisements, measure their effectiveness, and to understand the usage and visitation of our Services and the other applications and websites tracked by these companies. We do not have access to or control over cookies, platform device identifiers, software agents, or other technologies that they may use. You can manage your consent to how such data is collected and how we share Personal Information for re-marketing or re-targeting;
Exercising our rights: We may use your Personal Information to exercise or protect our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our terms and conditions, to respond to requests from law enforcement or other third parties, and to secure the Services;
Complying with our obligations: We may process your Personal Information to comply with legal or regulatory requirements, where this is required by law, such as in response to court orders or to comply with privacy or financial regulations;
Customizing your experience: When you use the Services, we may use your Personal Information to improve your experience, such as by providing interactive or personalized elements and providing you with content based on your interests; and
Protecting against harm: We may use Personal Information as necessary to protect the rights and safety of Innerlair, you, or others.

We rely on the following legal bases to process your Personal Information as described above:

Provide our Services to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our Services, we use your information to maintain your account to make it viewable to other users and recommend other users to you.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
How We Share Your Information

We are not in the business of selling your information. We consider this information to be a vital part of our relationship with you. We share your information with our service providers, in connection with a business transaction, to comply with the law and to protect our legal rights. The legal basis for this is our legitimate interest in providing our services, complying with the law and protecting our rights and those of others. We apply appropriate safeguards for this sharing of your information as described below.

Related companies. We share your personal information with our related companies (such as with subsidiaries, joint ventures, or affiliates) in the course of our normal business operations and for purposes consistent with this Privacy Policy.
Business transfers. As we develop our business, we might sell or buy businesses or assets. In the event that we enter into, or intend to enter into, a corporate sale, merger, reorganization, dissolution, bankruptcy or liquidation or similar event, your information may be part of the transferred assets.
Third party service providers. Like many businesses, we may sometimes hire other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
To protect our content and services. We use your information to prevent potential fraud, abuse or other illegal activities and to enforce our terms and conditions. We also use a variety of technical systems to detect and address anomalous activity and to screen content to prevent abuse, such as spam.
Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Website. These companies may use information about your visits to our Website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about services of interest to you.
With your Consent. We may disclose your personal information for any other purpose with your consent.
How Long We Retain Your Personal Information

If you leave a comment, the comment and its metadata are retained indefinitely. This is in order to recognise and approve any follow-up comments automatically instead of holding them in a moderation queue. We retain your data for the following lengths of time:

For email addresses if you’ve OPTED IN to an email list, we retain these until you unsubscribe (which can be done by clicking the link at the bottom of every email we send).
Emails you send to us are usually retained for two (2) years and then they’re cleaned up and deleted. If you send us an email or get in contact with us, the message and its contents will usually be kept for about two years unless you request we remove your data.
For customer information and data on purchases of our products, we retain this data for a period of five (5) years or more, as it’s required for accounting purposes. That being said if a customer unsubscribes from an email list after buying, we still respect that and only keep your email address in the form of your receipt of purchase, which we still have to keep. Personal information for Innerlair’s users is processed by Paypal and Stripe.

International Data Transfer

Sharing of Personal Information as described herein may involve cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their Personal Information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring Personal Information, binding them to protect the privacy and security of your data.

Links To Third-Party Websites

This Privacy Policy only addresses the collection, processing and use (including disclosure) of Personal Information by us. This Website may contain various links to third-party websites. These websites may provide additional information, products, services and/or promotions. These sites are owned and operated independently of Innerlair and have their own separate privacy and data collection practices. Any information you provide to these websites will be governed under the terms of their privacy policy, if any. Innerlair has no responsibility or liability whatsoever for the independent actions or policies of these independent sites, and is not responsible for the content or privacy practices of such websites.

How Do we Protect Your Personal Information

Innerlair takes reasonable steps to protect the Personal Information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. If you’re just a website viewer, your data (mainly cookies) is protected and processed by Google Analytics. Email addresses are held and processed by Aweber. However, you understand that no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Information to Innerlair via the Services.

Our Policy On Children

We do not knowingly solicit Personal Information from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that Personal Information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such Personal Information from our records. If you become aware of any Personal Information we have collected from children under age of 18 years, please contact us at: contact @ innerlair.com.

EEA Residents

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Our privacy practices intend to meet the requirements of the General Data Protection Regulation of the European Union (“GDPR”). If you wish to be informed about what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. Under GDPR, EAA residents have specific rights related to their Personal Information.

Right to access: You have the right to request access to your Personal Information held by us. Request is to be made in writing, electronically and information will be provided in a commonly used electronic format. Request will be handled within one month of receipt of the request, and free of charge with exception of where requests are manifestly unfounded or excessive, we hold the right to charge reasonably fee taking into account the administrative costs of providing that information.
Right to rectification: You have the right to have Personal Information rectified if inaccurate or incomplete. Where the Personal Information in question has been disclosed to a third party, they will be made aware of the rectification where possible.
Right to erasure: You have the right to request the deletion or removal of Personal Information in the following circumstances:
Where the Personal Information is no longer necessary in relation to the purpose for which it was originally collected/processed.
When you withdraw consent.
When you object to the processing and there is no overriding legitimate interest for continuing the processing.
The Personal Information was unlawfully processed.
The Personal Information has to be erased in order to comply with a legal obligation. This does not provide an absolute “Right to be forgotten”.

Where the Personal Information in question has been disclosed to a third party, we will inform them about the erasure of the Personal Information, unless it is impossible or involves disproportionate effort to do so. Personal Information will be erased by removal from our internal and cloud servers.

Right to restrict processing: You have a right to “block” or suppress processing of Personal Information if you contest its accuracy; have objected to the processing; processing is unlawful and you oppose erasure; we no longer need the Personal Information but you require the data to establish, exercise or defend a legal claim. Where the Personal Information in question has been disclosed to a third party, we will inform them about the restriction on processing of the data, unless it is impossible or involves disproportionate effort to do so.
Right to data portability: You have the right to obtain and reuse your Personal Information for your own purposes. Requests are to be made in writing, electronically, and will be handled within one month of receipt of the request.
Right to object: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics. Requests will be dealt with by immediate effect with no right for refusal.

Should a data breach occur, we have compliant procedures in place to investigate and report the matter to the individual. In the event of a breach, it will be reported to you within 72 hours of discovery. A record of any breaches will be kept by us. For this reason, make sure that if you’re subscribed to our email list you have set the emails to go to your inbox and not to be filtered to a spam folder or other folder, so that you can see them easily.

If you wish to exercise any of these rights, please contact us. In your request, please make clear: (a) what personal data is concerned; and (b) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your

request as soon as reasonably practicable and in any event, within one month of your request.

Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Californian Residents

This section applies to Californian residents and supplements the information contained in this Policy. It applies solely to all visitors, users, and others who reside in the State of California, the United States of America. We adopt this notice to comply with the California Consumer Privacy Act (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. As a California resident, you have the rights listed below, however, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting and/or selling Personal Information.
The categories of third parties with whom we share Personal Information.
Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.
Access. You can request a copy of the Personal Information that we have collected about you during the past twelve (12) months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. We share your Personal Information with third parties in the following circumstances, which California law classifies as a “sale” of your Personal Information:
supplying your data to third parties with your express consent (e.g. where you opt in to receive third party marketing or where you have requested to be contacted by a third party);
supplying your data to list brokers (but only where you have consented to be contacted by third parties);
supplying attendee data to third parties who provide services in connection with our events, and sending your data to suppliers of certain products and services (where you have consented to hear from such third parties);
like many companies, we use services that help deliver interest-based ads, content and services to you. California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads, content and services more likely to interest you.
Minors. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 16 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

You may exercise your California privacy rights by submitting a request form or emailing: contact @ innerlair.com quoting ‘California Privacy Rights’ in the subject header.

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

To learn about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

Opt Out Procedures

You can unsubscribe or opt-out of receiving marketing communications from the Services. This opt out messaging will appear at the bottom of every promotional email that is sent out. If you no longer wish to take advantage of the Services or receive any form of direct contact from us, whether it is email, discounts, newsletters, or other promotional offers or materials, contact us at: contact @ innerlair.com

Please note that even if you opt-out of receiving marketing communication, we may continue to send you non-marketing emails and other types of communications, as permitted by law, such as response to your support requests, or service email relating to your account.

Changes To This Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is published. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

Contact Us

We welcome your comments or questions about this Policy. You may contact us in writing at: help @ innerlair.com.

Your acceptance of this policy

By using our Services, you accept this Privacy Policy and consent to the contents of it including cookies and how we process your Personal Information. You have the right to disable cookies in your browser if you do not wish to be tracked with them, and if you do not accept this Privacy Policy then please do not use this website. Here’s a short summary:

Analytics and tracking cookies can be disabled by you in your internet browser if you don’t wish for us to use them
Other cookies are required by certain plugins to make them functional. For example, if you DON’T consent to those cookies you’re not able to (and shouldn’t try to) use the plugins and features on this site such as Redirected links.
Email addresses are only collected if you specifically OPT IN to a list by entering your email in an opt in form on this site and click subscribe, meaning you want to be emailed for marketing or other purposes. Again, you can unsubscribe at any time using the link at the bottom of the emails.
For customer information and data on purchases of our products, we retain this data for a period of five (5) years or more, as it’s required for accounting purposes. That being said if a customer unsubscribes from an email list after buying, we still respect that and only keep your email address in the form of your receipt of purchase, which we still have to keep.