Privacy Policy
Effective Date: January 01, 2024.
Last Updated: January 01, 2024.
1.0. Preamble
Please take the time and read this Privacy Policy carefully before continuing to use our website. Your use of our website and available services represents your agreement with all the provisions below.
This Privacy Policy together with our Terms and Conditions represent the rules governing your use of the website https://source.how/ (“the Website”).
SOURCE.how, the owner of the website, in its capacity of data controller, undertakes to respect your privacy and the data we collect about you. We take seriously our obligations regarding the protection of the personal data of our users and collaborators. As one of the essential principles of this legal framework is transparency, we have prepared this document to inform you about how we collect, use, transfer, store and protect your personal data when you interact with us in relation to our products and services, including through our website, or by e-mail.
Specific details regarding the way we collect and process your personal data might be included also in separate agreements in case you are a partner or an employee.
Your refusal to provide us with certain personal data will make it impossible for us to provide you with the desired products and/or services, or to respond to your request that you may address to us.
For any information regarding this Privacy Policy, or if you’d like to exercise any of your privacy rights, you can contact us by sending us and e-mail at: info@source.how or by sending us a letter by post, using the following details: SOURCE Media and Technology Corp., with headquarters in 48 Coffey St. Unit 1A, Dorchester MA 02122. We will do our best to reply to you within 30 days from the receipt of such a request.
2.0. What personal data we collect and how we use your information
2.1. Placing an order through our website
Data we collect: first name, last name, e-mail address, career level, professional discipline.
All the details regarding the payment (such as: e-mail address, card number, the issuing bank, expiry date, CVC code, name on the card, account holder, country, city, state, postal code, full address) are collected by our processor – HubSpot, on our behalf. We only have access to the following details: first name, last name, e-mail address, last 4 digits of the card number. Because HubSpot might also be an independent controller in relation to the data, please read carefully their Privacy Policy available here: https://legal.hubspot.com/privacy-policy. By placing an order in exchange for a fee, you also agree with HubSpot’s Terms and Conditions and Privacy Policy.
Other data that we might collect about you, in case you purchase a physical product: full delivery address and phone number.
The purpose of collecting the data: placing an order, paying the price of the order, delivering the order, reimbursing the paid amount in justified situations, other fiscal law requirements that we might be bound to respect in our activity.
The legal ground for processing the data: the conclusion and execution of a contract.
The data related to your career level, professional discipline is collected in our legitimate interest, to understand the specific needs of our users and to improve our service and products.
All the data we collect will be stored as long as it is necessary for achieving the purpose of the processing, but no longer than 10 years from the collection.
2.2 Accessing our website
When you access our website, our servers automatically create a record of your visit. These records usually include your IP address, the number of visits, the type of browser you are accessing our website from. We may also collect and further process certain information about your behavior while visiting our website in order to personalize your online experience and provide you with offers tailored to your profile. The purpose of data processing is to improve our website and services for the benefit of the users and the legal basis for the processing is our legitimate interest. Also, on our website we might collect information by using cookies and similar technologies.
2.3. Subscribing to our Newsletter
Data we collect if you subscribe to our newsletter: first name, last name, e-mail address, career level, professional discipline.
The purpose for collecting the data: sending you our newsletter.
The legal ground for collecting the data: your consent. Please note that you can unsubscribe at any time from receiving our newsletter, following the instructions you receive in each newsletter, only with effect for the future.
The data related to your career level and professional discipline is collected in our legitimate interest, to personalize the content of the newsletter you receive from us.
2.4. Sending us suggestions by using our Suggestion Box
Data we collect: name, e-mail address, the details of your messages, other data that you might send to us and that we don’t particularly request.
The purpose for collecting the data: providing a way to support our users so that SOURCE.how can meet any problems they may encounter in using the website.
The legal ground for collecting the data is the legitimate interest of our company to provide assistance to users and to resolve their possible complaints or suggestions of improvement.
The duration of the processing of the data is 90 days from the receipt of your message in this regard.
2.5. Data we collect about our partners
In addition to the information we might include in a separate agreement, we collect the following details about our partners: full name, e-mail address, the picture of our contributors and their Linkedin profile. The legal ground for the processing is the contract.
3.0. Where we store your data
Currently, we store, process, and share your data with the processors in the U.S. We will always take all the necessary steps to make sure your data is handled carefully in order to protect your rights. Any data transfer to our processors will always be protected by contractual commitments.
4.0. Retention period
We delete your personal data within a reasonable period after the purpose of the processing is fulfilled (or any subsequent purpose that is compatible with the original purpose). In order to determine the appropriate retention period for each personal data we collect, we rely mainly on the following criteria: the type of the collected data, regulatory requirements that we are subject to, including laws and regulations related to tax, employment, accounting, limitation periods etc.
5.0. How we share and disclose your data
When applicable, we can share your data with the following entities:
a) With our service providers who host and maintain our website, provide cloud services, send e-mails on our behalf, assist with customer support, provide market research or analytics, assist in order fulfillment, assist in the organization of possible contests on our website etc.
b) With our payment processor.
c) With our business partners – for instance, we may share your data with entities with whom we run a joint promotion etc.
d) With law enforcement, government bodies, and other officials as required to comply with the law.
e) With other parties as reasonably necessary to protect our rights.
Without limiting the above-mentioned provisions, in our sole discretion, we might share aggregated information which does not identify you.
6.0 Your Privacy Rights
As a U.S. citizen, where provided for by applicable federal or state privacy laws, you might be entitled to exercise some or all of the following rights:
a) Right of access – you have the right to know whether we process personal data about you and to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months.
b) Right to correct or update – you have the right to request us to correct or to update the personal data we process about you.
c) Right to delete – you have the right to request that we delete any of your personal information that we process about you, by respecting the conditions provided by the applicable legislation.
d) Right to opt-out of automated decision-making – you have the right to request to opt-out of any profiling or automated decision-making, when applicable in our activity.
e) Right not to sell your personal information or share your personal information for behavioral advertising – in this respect and when applicable in our activity, you can opt-out as instructed on the page you opted-in.
Also, please note that California law permits the consumers in California to request certain details about how their personal information is shared with third parties for their own direct marketing purposes, one time per year.
If you are an E.U. citizen (U.K. also included), you have the following rights, if all the conditions stated in the General Data Protection Regulation (“GDPR”) are fulfilled: the right to be informed (art. 12-14 GDPR); the right of access (art. 15 GDPR); the right of portability when applicable, in accordance with art. 20 GDPR; the right to rectification (art. 16 GDPR); the right to erasure (art. 17 GDPR); the right to restrict the processing (art. 18 GDPR); the right to object (art. 21 GDPR); the right to withdraw consent, if the legal ground of the processing is the consent, with effect only for the future. You can also make a complaint with your National Data Protection Authority about the way we process your data.
If you’d like to exercise one of the above mentioned rights or you’d like to find out more about the way we collect and process your personal data, please send us an e-mail at info@source.how or a letter by post, using the following details: SOURCE Media and Technology Corp., with headquarters in 48 Coffey St. Unit 1A, Dorchester MA 02122. We will do our best to reply to you within 30 days from the receipt of such a request.
Please note that the exercise of any of your rights is free of charge and that we might need to verify your identity before answering your request.
7.0. Measures taken to ensure the security of the processing of your personal data
7.1. We have taken all the appropriate technical and organizational measures, in accordance with the industry standards, to protect your personal data against accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access.
7.2. The transmission of your personal data is done using state-of-the-art encryption algorithms and we store them on secure servers.
7.3. We make all reasonable, commercially justified efforts to protect the personal data collected and periodically analyze new technologies in the field and, if necessary, apply them in order to improve our security systems.