I.  INTRODUCTION

This Privacy Policy (“Privacy Policy”) describes how Sylvia Says LLC, an Illinois limited liability company (“Company,” “we,” or “us”), collects, uses, discloses, and protects personal information obtained from you when you visit our website or contact us through email (the “Site”).

Please read this Privacy Policy carefully.  By accessing or using the Site, you consent to our collection, use, and disclosure of personal information as described in this Privacy Policy.  If you do not accept this Privacy Policy, you should leave and discontinue all use of the Site.

U.S.-Based Operations.  The Site is operated from, and intended for users located in, the United States.  By using the Site, you understand and agree that your personal information will be collected, processed, and stored in the United States.  If you are located outside the United States, please do not provide personal information through the Site.

Relationship to Terms of Use.  Please also review our Terms of Use located at [Terms of Use Link], which govern your use of the Site and incorporate this Privacy Policy by reference.

II.  DEFINITIONS

“Personal Information”  means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined under applicable law (e.g., the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”)).

“Sensitive Personal Information”  means the subset of Personal Information that reveals a consumer’s precise geolocation, racial or ethnic origin, religious or philosophical beliefs, citizenship or immigration status, genetic data, biometric data processed for the purpose of uniquely identifying a consumer, health information, sex life or sexual orientation, account log-in credentials, social security or government-issued identification numbers, or the contents of mail, email, or text messages, as defined under applicable state laws.

“Sale”  has the meaning given to that term under applicable state law and generally means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating Personal Information to a third party for monetary or other valuable consideration.

“Sharing”  means disclosing Personal Information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

“Service Provider”  means a person or entity that processes Personal Information on our behalf pursuant to a written contract, for a business purpose.

“Third Party”  means any person or entity that is not Sylvia Says LLC or a Service Provider.

“Cookies”  means small data files placed on your device that allow us, or third parties, to recognize your browser or device and collect certain information.

“Site”  means the Sylvia Says LLC website and any related services or features made available by us through the website.

III.  PERSONAL INFORMATION WE COLLECT

Categories of Personal Information Collected.  Consistent with the CCPA/CPRA framework, we may collect the following categories of Personal Information about you:

• Identifiers:  name, postal address, email address, telephone number, and similar contact identifiers you voluntarily provide.

• Internet or Other Electronic Network Activity Information:  IP address; domain and host names; the URL of any site from which you linked to the Site; browser type and language; device identifiers; operating system; time and date stamps; pages viewed; the order in which pages are viewed; time spent on pages; and information collected through Cookies and similar technologies.

• Commercial Information:  records of your registration for or attendance at events, and (if and when offered) any goods or services purchased or considered.

• Geolocation Data:  general (non-precise) location inferred from your IP address.  We do not collect precise geolocation data.

• Communications and Submissions:  the contents of emails, contact-form messages, mailing-list sign-ups, and any article, comment, question, or other submission you choose to send to us.

• Inferences:  limited inferences drawn from the above, used to understand visitor interests and improve the Site.

Sources of Personal Information.  We collect Personal Information: (a) directly from you when you provide it to us (e.g., by signing up for the mailing list, sending an email, or submitting a contact form); (b) automatically through your interaction with the Site (e.g., via Cookies, log files, and analytics tools); (c) from social-media platforms when you interact with our pages or content on those platforms; and (d) from Service Providers acting on our behalf.

Business and Commercial Purposes for Collection.  We collect and use Personal Information to: (a) operate, maintain, secure, and improve the Site; (b) communicate with you, including by sending mailing-list newsletters, event announcements, and articles you have requested; (c) respond to your inquiries and Submissions; (d) perform analytics and Site security functions; (e) comply with applicable law and legal process; (f) protect our rights, property, and the safety of others; and (g) for any other purpose disclosed to you at the time of collection or to which you consent.

Categories of Third Parties to Whom We Disclose.  We may disclose Personal Information to: (a) Service Providers (such as hosting providers, email-distribution providers, and analytics providers) under contractual confidentiality and use restrictions; (b) legal, regulatory, or government authorities, as required by law or legal process; (c) our professional advisors (such as legal counsel and accountants); and (d) a successor entity in connection with a merger, acquisition, sale of assets, reorganization, or similar transaction.

No Sale; No Sharing; No Targeted Advertising; No Profiling.  We do not sell your Personal Information.  We do not share your Personal Information for cross-context behavioral advertising.  We do not engage in targeted advertising or profiling that produces legal or similarly significant effects concerning you.  We have not done so in the preceding twelve (12) months.

Sensitive Personal Information.  We do not knowingly collect or use Sensitive Personal Information as defined under applicable state privacy laws (including, by way of example, precise geolocation, biometric data, health information, racial or ethnic origin, religious beliefs, sex life or sexual orientation, citizenship status, or account log-in credentials).  If we collect such information in the future, we will update this Privacy Policy and provide any required notice or right to limit use.

IV.  HOW WE USE PERSONAL INFORMATION

We use Personal Information for the purposes identified in Section III above, including, without limitation, to:

• operate, maintain, secure, and improve the Site;

• communicate with you, including sending mailing-list emails, event announcements, articles, and other content you have requested or consented to receive;

• respond to your inquiries, contact-form messages, and Submissions;

• perform analytics to understand how the Site is used;

• detect, prevent, and address technical issues, fraud, or abuse;

• comply with applicable law and legal process, including responding to lawful requests from public authorities;

• protect our rights, property, and the safety of our users and the public; and

• for any other purpose disclosed at the time of collection or to which you consent.

V.  PERSONAL INFORMATION WE DISCLOSE

Affiliates and Business Partners.  We do not rent or sell your Personal Information to unaffiliated third parties for mass-marketing purposes.  We may share Personal Information collected through the Site with our affiliated entities and strategic business partners, who may use it to contact you regarding information or services that may be of interest, or as otherwise required or permitted under applicable law.  At present, Sylvia Says LLC has no affiliated entities and no strategic business partners; this subsection is included to anticipate possible future arrangements, which will be subject to the limits set forth in Section III above.

Service Providers.  We may share Personal Information with companies that perform services on our behalf, including hosting, mailing-list distribution, and analytics providers.  Service Providers are bound by contract to use Personal Information only as necessary to perform services for us and to protect it consistent with this Privacy Policy.

Law Enforcement and Protection.  We may disclose your Personal Information when we believe disclosure is appropriate to comply with the law (including a court order or subpoena); to prevent or investigate a possible crime, such as fraud or identity theft; to enforce the terms that govern your use of the Site; or to protect the rights, property, or safety of our Site, other users, or third parties.  We also reserve the right to report to appropriate law enforcement or government agencies any activities that we, in good faith, believe to be harmful or unlawful, with or without providing notice to you.

Business Transfers.  All Personal Information and other content submitted by you to us is treated as a business asset, and may be transferred to another organization that acquires an ownership interest in the stock or assets of our organization, including as a result of a sale, merger, reorganization, dissolution, or liquidation.

Aggregated or De-Identified Information.  We may use and disclose aggregated or de-identified information that cannot reasonably be used to identify you for any lawful purpose.

Payments.  Although we do not currently sell products or services through the Site, if we do in the future, payments will be processed by a third-party payment processor.  We do not take possession of or retain your credit-card, debit-card, or other bank-account information; that information is collected and processed directly by the third-party payment processor, which has represented to us that it is PCI-DSS compliant, and is governed by the payment processor’s own privacy policy.

VI.  COOKIES, ANALYTICS, AND TRACKING TECHNOLOGIES

Types of Cookies and Similar Technologies.  The Site uses Cookies, web beacons, pixels, and similar technologies, which may include: (a) strictly necessary Cookies required for the Site to function; (b) functional Cookies that remember your preferences; (c) analytics Cookies that help us understand how visitors use the Site; and (d) (if/when used) advertising Cookies.  At present, we do not use advertising Cookies or other Cookies for cross-context behavioral advertising.

Third-Party Analytics.  We may use third-party analytics services, such as Google Analytics, to help us understand Site usage.  You can opt out of Google Analytics by installing the Google Analytics opt-out browser add-on available at tools.google.com/dlpage/gaoptout.

Do Not Track.  Because there is no industry-standard interpretation of “Do Not Track” signals, the Site does not currently respond to such signals.

Global Privacy Control (GPC).  We honor the Global Privacy Control signal as an opt-out of sale and sharing to the extent applicable.  Because we do not sell or share Personal Information, the GPC signal has no practical effect on our processing at this time.

Managing Cookies.  You can manage Cookies through your browser settings.  Disabling certain Cookies may affect Site functionality.  Users in California, Colorado, Connecticut, and other states identified in Section XII have additional rights as set forth therein.

VII.  DATA RETENTION

We retain Personal Information only as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements.  Generally:

• Mailing-list email addresses and associated preferences are retained until you unsubscribe or otherwise request deletion;

• The contents of inquiries, contact-form messages, and Submissions are retained for up to three (3) years after our last interaction with you, unless a longer period is required by law or necessary to resolve a dispute;

• Site analytics logs are retained for up to twenty-six (26) months;

• Records related to legal, tax, accounting, or compliance obligations are retained for the period required by applicable law; and

• Backups containing Personal Information are retained for the period of our standard backup cycle and are deleted in the ordinary course.

VIII.  ONLINE SECURITY; BREACH NOTIFICATION

We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information from unauthorized access, use, disclosure, alteration, or destruction.  However, no method of transmission or storage over the Internet is 100% secure, and we cannot guarantee absolute security.  If we become aware of a security incident affecting your Personal Information, we will notify you and, where required, regulatory authorities in accordance with applicable state breach-notification laws, including the Illinois Personal Information Protection Act (815 ILCS 530/10) and the California data-breach notification statute (Cal. Civ. Code § 1798.82).

IX.  CHILDREN

The Site is intended for adults at least eighteen (18) years of age and is not directed to children.  We do not knowingly collect Personal Information from individuals under 18.  If we learn that we have inadvertently collected Personal Information from a child under 13 without verifiable parental consent, we will promptly delete such information in accordance with the Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq.  For California residents under the age of 16, we do not sell or share Personal Information without the affirmative authorization required by the CCPA/CPRA.  Parents or guardians who believe their child has provided Personal Information to us may contact us at [CONTACT EMAIL] to request deletion.

X.  THIRD-PARTY LINKS AND PRACTICES

Links to Third-Party Websites.  The Site may contain links to other websites or may interact with third-party service providers.  We do not take any responsibility for monitoring these links or service providers, and inclusion of these links should not be construed as any sort of affiliation, sponsorship, endorsement, or approval.  You should review the privacy policies of other websites carefully before providing any information to such websites.  We shall not be responsible or liable for any information, opinions, goods, or services available on or through any third-party website, or any third-party website’s privacy practices.

Submissions.  The Site does not currently permit public posting of user content.  If you choose to submit content to us privately (e.g., by email, contact form, or mailing-list reply), please refer to Section IV of our Terms of Use, which governs the treatment of such Submissions.  Personal Information contained in any Submission will be handled in accordance with this Privacy Policy.

XI.  YOUR PRIVACY RIGHTS

A.  Marketing Communications.  You may unsubscribe from our mailing list and similar marketing communications at any time by clicking the “unsubscribe” link in any commercial email we send you or by contacting us at [CONTACT EMAIL].  We will honor opt-out requests in accordance with the CAN-SPAM Act, 15 U.S.C. § 7701 et seq.

B.  Submitting a Privacy Rights Request; Verification.  You may submit a privacy rights request to us by email at [CONTACT EMAIL] or by mail at [Company Mailing Address].  Please include your name and sufficient information to enable us to locate your records.  We will verify your identity by matching information you provide with information we have on file (e.g., your email address).  For sensitive or higher-risk requests, we may require additional verification.

C.  Authorized Agents.  You may designate an authorized agent to submit a privacy rights request on your behalf.  We may require the agent to provide written authorization signed by you and verification of the agent’s identity, and we may verify the request directly with you.

D.  Response Timing and Appeals.  We will respond to verified consumer requests within forty-five (45) days of receipt.  We may extend the response period by an additional forty-five (45) days when reasonably necessary, with notice to you.  Requests are generally free of charge, except for excessive or repetitive requests, for which we may charge a reasonable fee or decline to act, as permitted by law.  If we deny your request, you may appeal the decision by emailing us at [CONTACT EMAIL] within sixty (60) days of our denial.  We will respond to your appeal within forty-five (45) days (sixty (60) days for Colorado residents).  If the appeal is denied, you may have the right to file a complaint with the attorney general of your state.

E.  Right to Non-Discrimination.  We will not discriminate against you for exercising any of your privacy rights, including by denying goods or services, charging different prices, providing a different level of quality, or suggesting that you will receive any of the foregoing.

XII.  STATE-SPECIFIC PRIVACY RIGHTS

A.  California Residents (CCPA/CPRA).  If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

• Right to Know.  Right to request the categories and specific pieces of Personal Information we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we have disclosed Personal Information, in the preceding twelve (12) months (or longer, where the CPRA so provides).

• Right to Delete.  Right to request deletion of Personal Information we have collected from you, subject to statutory exceptions.

• Right to Correct.  Right to request that we correct inaccurate Personal Information we maintain about you.

• Right to Opt Out of Sale or Sharing.  As noted, we do not sell or share Personal Information.  If our practices change, we will provide a “Do Not Sell or Share My Personal Information” link on the Site.

• Right to Limit Use of Sensitive Personal Information.  As noted, we do not use Sensitive Personal Information for purposes that would trigger this right.

• Right to Data Portability.  Right to receive your Personal Information in a portable and, to the extent technically feasible, readily usable format.

• Right to Non-Discrimination.  As set forth in Section XI.E above.

Shine the Light (Cal. Civ. Code § 1798.83).  California residents may request, once per calendar year, information regarding Personal Information we disclosed to third parties for their direct-marketing purposes in the preceding calendar year.  To make such a request, please email [CONTACT EMAIL].  We do not currently disclose Personal Information to third parties for their direct-marketing purposes.

California Consumer Affairs Notice (Cal. Civ. Code § 1789.3).  Pursuant to California Civil Code § 1789.3, California users are entitled to the following consumer rights notice: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Boulevard, Suite N 112, Sacramento, California 95834, or by telephone at (800) 952-5210.

B.  Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia Residents.  If you are a resident of one of these states, you have, subject to the exceptions and limitations of your state’s law, the following rights:

• Right to confirm whether we process your Personal Information and to access that Personal Information.

• Right to correct inaccurate Personal Information (except in Iowa and Utah, where the right to correct does not apply).

• Right to delete Personal Information you have provided or that we have obtained about you.

• Right to data portability.

• Right to opt out of the sale of Personal Information, processing for targeted advertising (except Iowa), and profiling in furtherance of decisions that produce legal or similarly significant effects (except Iowa and Utah).

• Right to limit or require consent for the processing of Sensitive Personal Information.

Universal Opt-Out Signals.  We recognize the Global Privacy Control (GPC) signal as a valid opt-out request for sale and sharing, as required by Colorado and Connecticut law.  Because we do not sell or share Personal Information, GPC will have no practical effect on our processing at this time.

Appeals.  As described in Section XI.D above, you have the right to appeal a denial of your request.  Colorado residents whose appeal is denied may contact the Colorado Attorney General to submit a complaint.  Residents of other states may similarly contact their state attorney general.

C.  Other Jurisdictions.  We will comply with applicable U.S. state privacy laws as they come into effect.  Residents of jurisdictions not specifically listed above may have additional rights under local law.  This Privacy Policy is not designed for residents of the European Union or the United Kingdom; residents of those jurisdictions should not provide Personal Information through the Site.

XIII.  CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time, including to reflect new uses of Personal Information.  For any material change, we will provide affirmative notice to users by email (to mailing-list subscribers and other users for whom we have an email address) and/or by posting a prominent banner or notice on the Site at least thirty (30) days before the change takes effect, and any new material terms will apply only prospectively.  Any significant change in the way we use or disclose Personal Information will not apply to Personal Information previously collected unless we obtain your consent, where required by applicable law.  We will update the “Last Updated” date above whenever we make changes.  We will review this Privacy Policy at least annually.

XIV.  CONTACT US

If you have questions about this Privacy Policy, wish to make corrections to Personal Information, or have any other questions or comments concerning the Site, please contact us at:

Sylvia Says LLC

[Company Mailing Address]

Email:  [CONTACT EMAIL]

Telephone:  [Phone Number]

Accessibility.  If you have a disability and require this Privacy Policy in an alternate format, please contact us at [CONTACT EMAIL], and we will work to provide a reasonable accommodation.