Your privacy is critically important to us. At Valley Letter Media, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We use as few cookies as possible.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
Below is our Privacy Policy, which incorporates and clarifies these principles.
Information We Collect
We only collect information about you if we have a reason to do so — for example, to add you as a free or paying member, to communicate with you, or to make our services better.
We collect this information from three sources:
- if and when you provide information to us
- automatically through operating our services
Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:
- Basic account information: We ask for basic information from you in order to set up a free account. For example, we require individuals who sign up for a Valley Letter account to provide an email address — and that’s it.
- Public profile information: If you have an account with us, we collect the information that you provide for your public profile. Our system uses your email to pull in your Gravatar image, if you have created one. This is used, for example, to put that image next to your username when you comment.
- Payment and contact information: If you become a paid subscriber or buy something from us, we’ll collect information to process those payments and contact you, including your name, credit card information, and contact information. We also keep a record of the purchases you’ve made for tax and accounting purposes.
- Content information: You might provide us with information about you in draft and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
- Communications with us: You may also provide us with information when you respond to surveys, communicate with us about a support question, post a comment, or sign up for an event. When you communicate with us via form, email, or otherwise, we store a copy of our communications.
Links to other websites and services
Our website may integrate with or contain links to other third party sites and services, such as an embedded social media post or hosted video. While we strive to keep cookies to a minimum, we are not responsible for the practices employed by third party websites or services embedded in, linked to, or linked from our website. Your interactions with any third-party website or service are subject to that third party’s own rules and policies.
Information We Collect Automatically
We also collect some information automatically:
- Usage information: We collect information about visitors’ usage of our website. For example, when you use our services (e.g., page views). We use this information to, for example, provide our services to you, get insights on how people use our services so we can make our services better, and understand and make predictions about user retention.
- Location information: Our publishing system may attempt to determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate roughly how many people visit our services from certain geographic regions.
- Interactions with other users’ sites: Our commenting system, currently Cove, collects some information about your interactions with other users’ sites while you are logged in to your account with us, such as your “Reactions” to other comments and the fact that you commented on a particular post.
How and Why We Use Information
Purposes for Using Information
We and our partners use information about you for the purposes listed below:
- To provide our services. For example, to set up and maintain your account, deliver newsletters, provide customer service, process payments and orders, and verify user information.
- To ensure quality, maintain safety, and improve our services. For example, by monitoring and analyzing how users interact with our services so we can create new features that we think our users will enjoy or make our services easier to use.
- To protect our services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Valley Letter Media and others, which may result in us, for example, declining a transaction or terminating services.
- To fix problems with our services. For example, by monitoring, debugging, repairing, and preventing issues.
- To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Valley Letter Media.
Legal Bases for Collecting and Using Information
A note here for those in the European Union or United Kingdom about our legal grounds for processing information about you under EU and UK data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan (in other words, our processing is necessary to enter into, or perform, a contract with you); or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information — for example, to provide and update our services; to improve our services so that we can offer you an even better user experience; to safeguard our services; to communicate with you; and to understand our user retention and attrition; to monitor and prevent any problems with our services; or (5) You have given us your consent. We process collected data for as long as necessary to provide our services.
Sharing Information
How We Share Information
We share information about you in limited circumstances, and with appropriate safeguards for your privacy.
- Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
- Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you or your site. This includes vendors that help us provide our services to you (like Stripe, which powers subscription payments, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, registrars, registries, those that host our website, assist us with our marketing efforts; those that help us understand and enhance our services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); and other third-party tools that help us manage operations. We only use vendors that agree to similar privacy commitments in order to share information with them.
- Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Valley Letter Media, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Valley Letter Media goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
- With your consent: We may share and disclose information with your consent or at your direction.
- Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about how many subscribers we have, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request (without your name or identifying information attached) in order to clarify or respond to your request, or to help us support other users.
We do not sell our users’ data.
We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails. We may show ads at some point but will not do so in a way that turns over personally-identifable information about you to an advertiser.
Under a new California law, the California Consumer Privacy Act (“CCPA”), some personalized advertising you see online might be considered a “sale” even though we don’t share information that identifies you personally, like your name or email address.
Information That You Share Publicly
Information that you choose to make public is — you guessed it — disclosed publicly.
That means information like your comments are all available to others — and we hope they get a lot of views!
Once you make something public, neither you nor we have any realistic control over it — for example, someone could re-post your comment to another site, or screenshot it and share it. You can delete your comment from the Valley Letter website if you like.
Security
While no online service is 100% secure, we and our partners work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We and our partners monitor our services for potential vulnerabilities and attacks.
Choices
You have several choices available when it comes to information about you and communications:
- Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our services — for example, paid subscriber-only posts may not be accessible.
- Set your browser to reject cookies: At this time, Valley letter Media does not respond to “do not track” signals, but you can still block cookies in your browser or tracking pixels in your email client.
- Unsubscribe from our newsletters: Free and paid subscribers may unsubscribe from our newsletter at any time, either through the unsubscribe link at the end of every newsletter or on the website in your account settings. You cannot opt out of Service-related communications (e.g., account verification, payment confirmation, changes/updates to our products or features, technical and security notices.)
- Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our services.
Your Rights
If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”) or the UK’s GDPR, you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.
European General Data Protection Regulation (GDPR) / UK GDPR
If you are located in a country that falls under the scope of the GDPR, or are in the UK, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You also have the right to make a complaint to a government supervisory authority.
For processing based on your consent, you can withdraw your consent at any time.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we and our service providers collected the following categories of personal information from California residents, depending on the services used:
- Identifiers (like your name, contact information, and email address);
- Commercial information (your billing information and purchase history, for example);
- Internet or other electronic network activity information (such as your usage of our services, like the actions you take as paid subscriber);
- Geolocation data (such as your location based on your IP address);
- Audio, electronic, visual or similar information (such as your profile picture, if you use Gravatar);and
- Inferences we make (such as likelihood of retention or attrition).
If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:
- Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
- Request deletion of personal information we collect or maintain;
- Opt out of any sale of personal information; and
- Not receive discriminatory treatment for exercising your rights under the CCPA.
Contacting Us About These Rights
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, contact us by going to your account on our site and clicking Contact Support.
When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.
A note about processing locations
We are based in the USA, and process personal data here. Because you are visiting our site and providing personal data directly to us, there is no “transfer” from an EU or UK GDPR point of view.