Twofold LLC / Eli Natoli Privacy & Cookies Policy, updated 05.21.18
In order for us to operate our business and provide our services to you, we sometimes need to collect or process information about you. This information usually comes in one of the following forms:
- Information that you provide to us directly, such as when you complete an online form or send us a message via our website (https://elinatoli.com), or enroll in a course via our Teachable platform (https://elinatoli.com);
- Information that is automatically sent to us by your computer’s internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on;
- Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.
Our commitment to data privacy
We are fully committed to maintaining the privacy of any information (‘personal data’) that you provide to us. We are equally committed to making sure that data is held securely, used appropriately and only retained for as long as is necessary.
Our systems and services are designed with privacy in mind, which means that we will only ever ask you for the minimum amount of information we need to provide the services you request.
We have no desire to retain (and maintain) any more information than is necessary. We aspire to comply to the fullest extent possible with all applicable data protection regulations, in particular the European Union’s General Data Protection Regulation (‘GDPR’) and ePrivacy Directive, where applicable.
Who we are
Eli Natoli is wholly owned and operated by Twofold LLC, a Limited Liability Company operating in the United States of America. In terms of your use of our websites, Twofold LLC acts in the capacity of “Data Controller.” If you have any questions or concerns about the data we hold about you, please feel free to contact us using the information below:
Data Controller: Twofold LLC
Correspondence address: 13134 Falls Road, Hunt Vally, Maryland 21030, USA
Email correspondence: email@example.com
Definition of “personal data”
“Personal data” means any information that allows us to identify you personally; for example, your name, email address, postal address etc.
We will always ask for your explicit consent to provide this information to us, and do all we can to make sure you fully understand how it will be used. For example, we use a double-opt-in process on all of our free materials to make sure we are authorized to collect your information.
Other types of information, such as your computer’s ‘IP’ address or broad geographical location do not allow us to identify you directly.
European data privacy regulations, in their current form, are a little vague. So because of that, we’d like to cover how we use your data in more detail.
Who we share data with
We want to stress that access to any data you provide is only given for reasons of technical support, and even then, only on an as-needed basis for that sole purpose.
We absolutely do not share your personal data with any other party, for any other reason, e.g. for marketing or advertising purposes.
We operate on a strict ‘need to know’ basis for all data that we work with, and that is particularly true for personal data. The only people/organizations that are granted access to personal data are:
- Members/employees of Twofold LLC who provide design and/or support services;
- Our web hosting technology suppliers (currently HostMonster and Teachable) who provide the physical server infrastructures that our website(s) operate on.
How your data is protected
We take the security of all personal data very seriously, and that data is protected in a number of ways:
Access to personal data is strictly limited in line with our policy detailed in the “who we share data with” section on this page. Access is controlled by individual user accounts, where a strong password policy is enforced.
No one has access to your password except you.
The most we can do is reset it for you if you request us to do so.
Dedicated security software:
We operate dedicated security scanning and access control software on all of our websites. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.
Where data is stored in a cloud facility (such as the storage of website backup files), that data is encrypted both ‘in transit’ and ‘at rest’ – meaning that all data is securely obscured both during the process of transfer to the cloud provider, and then additionally when it is in storage at its final location.
Additionally, we host our websites on a dedicated, secure Virtual Private Server (VPS).
Selection of third party service providers:
We use a very limited number of third party service providers, but some are essential for the provision of physical hosting environments and cloud services. We evaluate these providers on, among other things, their ability to provide secure systems and processes.
Access to your personal data
In any situation where you have directly provided personal information to us (such as by completing an online form, contacting us or enrolling in an online course), you have a number of rights regarding the personal data that we hold:
- You have the right to obtain from us confirmation about whether any such data is being held;
- You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
- Even if you have consented to Us processing your personal data, you have the right to withdraw that permission at any time;
- You have the right to require us to rectify any incomplete or incorrect information held about you;
- You have the right to require us to erase the data held about you (the ‘right to be forgotten’);
- In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies):
- You have the right to object to the legal basis upon which we are collecting this data, and We have an obligation to consider and respond to that objection;
- You have the right to request the prevention of further processing of your data while your objection is considered;
- You have the right to make a complaint to the relevant data protection authority (which, in the UK, is the Information Commissioner’s Office or ‘ICO’)
Types of data collected
Website contact forms
When you complete one of the contact forms on our website, we will ask you for a number of pieces of personal information, such as your name, email address and other contact details. This is obviously required for us to respond to your request.
If you don’t use or submit an online form on the website (https://elinatoli.com), or in our online school (http://selfstartsuccess), no data is collected.
For some website functionality (e.g. enrollment in online courses, access to your profile and course materials), we will need to create a user account for you that allows you to login to the site. We do this to ensure that only authorized individuals (i.e. YOU) can access your data and that functionality. Examples include when you make an online purchase via the website (https://elinatoli.com), or when you log in to access courses you are enrolled in via Teachable (http://selfstartsuccess).
The purpose of these user accounts is to protect your personal data behind login security, and to protect the integrity of our site and the servers that run it.
Data collected will generally involve your name and email address (which doubles as username) as a minimum, but may include your postal address if required for shipping of online purchases.
If you do not register for an online account, no data will be collected.
Technical data (such as ‘IP address’)
When you visit our website, our systems will log a record of your visit in our server logs. This record will include the technical ‘IP’ address that is associated with your device and the browser type and version that you are using.
Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behavior (such as repeated malicious attempts to access a system).
IP addresses do not allow us in any way to identify you as an individual.
We do not and will not ever use the content of server access logs to attempt to determine an identifiable individual.
Because of this, we do not consider data held within server logs to be within the scope of ‘personal data,’ and, accordingly, we do not seek your consent to collect it.
Cookies & ‘similar technologies’
We have included cookies, web beacons and similar technologies into this same section because even though they work slightly differently, they all perform similar functions.
All of these technologies allow us to better understand how people use our websites and other related services. They can also be an essential part of providing certain online functionality. They are all essentially small data files placed on your computer (or other device) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website.
These technologies are used by most websites as they provide useful insight into how the services are being used, as well as improving speed, performance and security, and enabling us to improve our personalization of your experience.
These are small text files placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:
- Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
- Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
- First-party cookies are set by the site you are visiting.
- Third-party cookies are set by a third party site separate from the site you are visiting.
There are a number of ways that you can influence how cookies are used on your particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet Explorer, Firefox etc) allow you to set preferences for whether to allow or block website cookies.
They will also provide tools that allow you to remove any cookies that have already been set. Using the ‘Help’ functionality of your browser, or an internet search, will help you to understand how to use these features for your particular browser.
Additionally, we have incorporated specific cookie functionality on our website that allows you to easily indicate when you first visit the site whether or not you are happy for cookies to be set on your device.
Ironically, for our site to remember your preference for whether to allow cookies or not, it is necessary for us to set cookies for this specific purpose.
When you first visit our site, a Cookie Control box will be displayed allowing you to choose whether to allow cookies or not. Only Essential cookies and those that do not contain/track any personal data will be set when you first visit our site.
You can change your choice at any time by clicking on the persistent cookie icon at the bottom of the screen.
These are small graphic images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites and services that typically work in conjunction with cookies to identify our users and user behavior.
We use Google Analytics to better understand what people look at on our website.
When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) is sent in an anonymous form to Google Analytics (which is controlled by Google).
The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from this data.
We ensure that no personally identifiable information is ever contained within the data sent to our analytics providers, and we also perform a process which partially obscures your IP address information.
Because analytics information is not personal data, we do not specifically ask for your prior consent.
Other Google Services
In addition to Google Analytics, we use a number of industry-standard Google services to provide particular pieces of website content. These include:
- Google Fonts: We may use one or more of Google’s web fonts to ensure that our website content is displayed in a clear and consistent fashion across all of the different types of devices and browsers.
- Google Maps: We may use the Google’s mapping services to provide dynamic geographic maps on our website
- Google Recaptcha: We may use Google’s Recaptcha service (which provides the ‘I Am Not A Robot’ functionality) on our web contact forms. This is a security measure to prevent the abuse of our contact forms by automated programs.
Each of these services involve our website making a connection to one or more Google servers, and may result in Google placing cookies on your device.
Like the vast majority of commercial websites, we use social media cookies from Facebook on our site. The cookies are placed by Facebook, and we use them to understand the effectiveness of social media campaigns that we operate.
If you’re not logged into Facebook when you view our site, then it is not possible for any personal information about your visit to be collected. As such, we do not specifically ask for your prior consent.
If you are logged into Facebook when you view our site, then Facebook will know when you visit us. We do not have any access to the detail of that personal data, as you have consented to share it with Facebook, not us. We only see anonymized data about the numbers of people who have responded to our advertising or other social media activity.
There are a number of ways of controlling the ads that you see based upon your activity on Facebook. The following resources may help to understand those choices:
How to opt-out of Facebook interest-based advertising on your browser or mobile device:
Your Online Choices:
You can always use your browser’s ‘private’ or ‘incognito’ mode to browse websites anonymously.
If you disable marketing cookies on this site, it does not mean that you won’t see our ads; it only means that they will not be personalized based on your Facebook activity.
© 2018 Twofold LLC