Privacy Policy

Last Updated: May 26, 2018

Intro & Data Usage

1.      Introduction

1.1    We are committed to safeguarding the privacy of Course Bistro website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of Course Bistro visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of Course Bistro website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4    Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive online, direct marketing communications and limit the use of your information. You can access the privacy controls by emailing jayna@coursebistro.com, or by unsubscribing at any time at the bottom of our emails.

1.5    In this policy, "we", "us" and "our" refer to Course Bistro, LLC. For more information about us, see Section 13.

2.      Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com).

3.      How we use your personal data

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)     the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

3.2    We may process data about your use of Course Bistro website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and the Facebook pixel. This usage data may be processed for the purposes of analyzing the use of the website and services and marketing efforts. The legal basis for this processing is our legitimate interests, namely monitoring and improving Course Bistro website and services for its visitors.

3.3    We may process your Personally Identifiable Information (PII) to fulfill a contract and/or improve your experience ("account data"). The account data may include your name, email address, credit card information or other details. The account data may be processed for the purposes of operating Course Bistro website, providing our services, ensuring the security of Course Bistro website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4    We may process your Personally Identifiable Information (PII) to fulfill a contract and/or improve your experience ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

3.5    We may process Personally Identifiable Information (PII) that are provided in the course of the use of our services ("service data"). The service data may include contact details, invoicing and account details, and specifications. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6    We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business AND the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract (for example, to deliver a “freebie” to your inbox).

3.7    We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent and our legitimate interests to provide you the best customer service possible.

3.8    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through Course Bistro website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

3.9    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. You may unsubscribe at any time by emailing jayna@coursebistro.com or by clicking the unsubscribe link in any email.

3.10  We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Course Bistro website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.11  We may process information relating to or contained in any communication that you send to us (“correspondence data”). The correspondence data may include content of any correspondence with Course Bistro and/or metadata associated with such communication. Course Bistro website may generate metadata associates with communications made using any Course Bistro contact forms. The correspondence data may be processed for the purposes of marketing, site optimization, product/service development, communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.12  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.13  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.14  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.15  Please do not supply any other person's personal data to us, unless we prompt you to do so.

4.      Providing your personal data to others   

4.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

4.2    Financial transactions relating to our website and services may be handled by our payment services providers, PayPal (https://www.paypal.com) and/or Stripe (https://stripe.com/). We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at their respective links above.

4.3    We may disclose contact details and information about your consignment for the reason of providing our services to you and for communicating with you before, during and after the event.

4.4    We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can provide the relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

4.5    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.6    We will not sell, loan or share your personal data to other organizations for the purposes of marketing their services unless you ask us to do so.

5.      International transfers of your personal data

5.1    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.      Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

(a)   Usage data will be retained indefinitely for the purpose of monitoring the historical performance of our website, however personal data beyond the ISP will not be linked to this data.

(b)   Account data will be retained for an additional two years after our last transaction with you, after which it will be deleted unless required for auditing or legal reasons.

(c)   Service data will be retained for an additional two years after our last transaction with you, after which it will be deleted unless required for auditing or legal reasons.

(d)   Associate profile data will be deleted on request or within two years of your last communication with us, after which it will be deleted unless required for auditing or legal reasons.

(e)   Enquiry data will be deleted on request or within two years of your last communication with us, after which it will be deleted unless required for auditing or legal reasons.

(f)    Transaction data will be retained for an additional two years after our last transaction with you, after which it will be deleted unless required for auditing or legal reasons.

(g)   Notification data will be retained for an additional two years after our last transaction with you, after which it will be deleted unless required for auditing or legal reasons.

(h)   Correspondence data will be retained for an additional two years after our last transaction with you, after which it will be deleted unless required for auditing or legal reasons.

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the period we need to access the data for the provision of services, receiving payment, resolving insurance or other issues or any other auditing or legal reasons.  The legal basis for this retention of personal data is our legitimate interests, namely the proper administration of our website and business.

6.5    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.      Amendments

7.1    We may update this policy from time to time by publishing a new version on our website. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy so you may determine any changes since your last visit.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    You may change your personal information and/or consent by emailing us at jayna@coursebistro.com.

8.      Your rights

8.1    In this Section 8, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)     the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)     the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

8.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You may obtain a copy of your personal data by emailing jayna@coursebistro.com.

8.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

8.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

8.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13  You may exercise any of your rights in relation to your personal data by emailing jayna@coursebistro.com.

Cookies, Use & Management

9.      About cookies

9.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10.    Cookies That We Use

10.1  We use cookies on the website and associated domains of www.coursebistro.com and mobile applications for the following purposes:

(a)  Authentication, Customization, Security and Other Functional Cookies. Cookies help us verify your Account and device and determine when you’re logged in, so we can make it easier for you to access the Services and provide the appropriate experiences and features. We also use cookies to help prevent fraudulent use of login credentials and to remember choices you’ve made on the Services, such as your language preference.

(b) Performance and Analytics. Cookies help us analyze how the Services are being accessed and used and enable us to track performance of the Services. For example, we use cookies to determine if you viewed a page or opened an email. This helps us provide you with information that you find interesting.

(c)  Third Parties. Third Party Services may use cookies to help you sign into their services from our Services. Any such third-party cookie usage is governed by the policy of the third party placing the cookie.

(d)  Opting Out. You can set your browser to not accept cookies, but this may limit your ability to use the Services. We currently don’t respond to DNT:1 signals from browsers visiting our Services. You can also opt out of receiving interest-based ads from certain ad networks here (or if located in the European Union, here).

(e)   Device Identifiers. We use device identifiers on this MemberVault site and mobile applications to track, analyze and improve the performance of the Services and our ads.

(f) Third Party Tags. We use and manage third party tags on this website. Third party tags may take the form of pixels or tracking snippets. We use pixels to learn how you interact with our site pages and emails, and this information helps us and our ad partners provide you with a more tailored experience. We use tracking snippets to capture data from your browser, make requests to a third-party partner or set cookies on your device to store data. We use Google Tag Manager to manage our third-party tag usage. This may cause other tags to be activated which may, for their part, collect data and set cookies under certain circumstances. Google Tag Manager does not store this data.

Analytics and Performance Cookies

We use Analytics and Performance cookies to collect information on your behalf about how visitors interact with your site. Storing these cookies is how we populate the data you find in analytics such as traffic sources, unique visitors, and cart abandonment.

The following is a list of analytics and performance cookies used on the Course Bistro website, their purpose and the duration for which those cookies are used:

• ss_cid (2 years) which identifies unique visitors and tracks a visitor’s sessions on a site.
• ss_cvr (2 years) which identifies unique visitors and tracks a visitor’s sessions on a site.
• ss_cvisit (30 min) which identifies unique visitors and tracks a visitor’s sessions on a site.
• ss_cvt (30 min) which identifies unique visitors and tracks a visitor’s sessions on a site.
• ss_cpvisit (2 years) which identifies unique visitors and tracks a visitor’s sessions on a site.
• ss_cookieAllowed (30 days) which remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies.

11.2    Analytics and Performance Cookies

We use Analytics and Performance cookies to collect information about how visitors interact with Course Bistro’s website. 

11.3  We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

12.    Managing cookies

12.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)     http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)     https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2  Blocking all cookies will have a negative impact upon the usability of many websites.

12.3  If you block cookies, you will not be able to use all the features on our website.

our details

Our Details

13.     Our details

13.1  This website is owned and operated by Jayna Pettersen.

13.2  Our principal place of business is at 11809 132nd St Ct E, Puyallup, WA 98374.

13.3  You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form;

(c)     by email, using jayna@coursebistro.com.

14.    Data protection officer

14.1  Our data protection officer's contact details are: Jayna Pettersen, Course Bistro, 11809 132nd St Ct E, Puyallup, WA 98374. Email: jayna@coursebistro.com.