We respect your privacy and are committed to protecting it through our compliance with this
you or that you may provide (“Personal Information”) on the joannabacas.com website (“Website”
or “Service”) and any of its related products and services (collectively, “Services”), and our
practices for collecting, using, maintaining, protecting, and disclosing that Personal
Information. It also describes the choices available to you regarding our use of your Personal
Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and this
Website operator (“Operator”, “we”, “us” or “our”). If you are entering into this agreement on
behalf of a business or other legal entity, you represent that you have the authority to bind
such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to
such entity. If you do not have such authority, or if you do not agree with the terms of this
agreement, you must not accept this agreement and may not access and use the Website and
Services. By accessing and using the Website and Services, you acknowledge that you have read,
understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the
practices of companies that we do not own or control, or to individuals that we do not employ or
Collection of personal information
You can access and use the Website and Services without telling us who you are or revealing any
information by which someone could identify you as a specific, identifiable individual. If,
however, you wish to use some of the features offered on the Website, you may be asked to
provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when you create an account,
make a purchase, or fill any forms on the Website. When required, this information may include
– Contact information (such as email address, phone number, etc)
– Basic personal information (such as name, country of residence, etc)
– Payment information (such as credit card details, bank details, etc)
– Any other materials you willingly submit to us (such as articles, images, feedback, etc)
You can choose not to provide us with your Personal Information, but then you may not be able to
take advantage of some of the features on the Website. Users who are uncertain about what
information is mandatory are welcome to contact us.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 18. If you
are under the age of 18, please do not submit any Personal Information through the Website and
Services. If you have reason to believe that a child under the age of 18 has provided Personal
Information to us through the Website and Services, please contact us to request that we delete
that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help
enforce this Policy by instructing their children never to provide Personal Information through
the Website and Services without their permission. We also ask that all parents and legal
guardians overseeing the care of children take the necessary precautions to ensure that their
children are instructed to never give out Personal Information when online without their
Use and processing of collected information
We act as a data controller and a data processor in terms of the GDPR when handling Personal
Information, unless we have entered into a data processing agreement with you in which case you
would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We
act in the capacity of a data controller when we ask you to submit your Personal Information
that is necessary to ensure your access and use of the Website and Services. In such instances,
we are a data controller because we determine the purposes and means of the processing of
Personal Information and we comply with data controllers’ obligations set forth in the GDPR.
We act in the capacity of a data processor in situations when you submit Personal Information
through the Website and Services. We do not own, control, or make decisions about the submitted
Personal Information, and such Personal Information is processed only in accordance with your
instructions. In such instances, the User providing Personal Information acts as a data
controller in terms of the GDPR.
In order to make the Website and Services available to you, or to meet a legal obligation, we
may need to collect and use certain Personal Information. If you do not provide the information
that we request, we may not be able to provide you with the requested products or services. Any
of the information we collect from you may be used for the following purposes:
– Deliver products or services
– Run and operate the Website and Services
Processing your Personal Information depends on how you interact with the Website and Services,
where you are located in the world and if one of the following applies: (i) you have given your
consent for one or more specific purposes; this, however, does not apply, whenever the
processing of Personal Information is subject to European data protection law; (ii) provision of
information is necessary for the performance of an agreement with you and/or for any
pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal
obligation to which you are subject; (iv) processing is related to a task that is carried out in
the public interest or in the exercise of official authority vested in us; (v) processing is
necessary for the purposes of the legitimate interests pursued by us or by a third party.
We rely on the following legal bases as defined in the GDPR upon which we collect and process
your Personal Information:
– User’s consent
Note that under some legislations we may be allowed to process information until you object to
such processing by opting out, without having to rely on consent or any other of the legal bases
above. In any case, we will be happy to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal Information is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.
In case of Services requiring payment, you may need to provide your credit card details or other
payment account information, which will be used solely for processing payments. We use
third-party payment processors (“Payment Processors”) to assist us in processing your payment
Payment Processors adhere to the latest security standards as managed by the PCI Security
Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and
Discover. Sensitive and private data exchange happens over a SSL secured communication channel
and is encrypted and protected with digital signatures, and the Website and Services are also in
compliance with strict vulnerability standards in order to create as secure of an environment as
possible for Users. We will share payment data with the Payment Processors only to the extent
necessary for the purposes of processing your payments, refunding such payments, and dealing
with complaints and queries related to such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you, which
allows them to process your payments (e.g., your email address, address, credit card details,
and bank account number) and handle all the steps in the payment process through their systems,
including data collection and data processing. Where necessary for processing future or
recurring payments and subject to your prior consent, your financial information will be stored
in encrypted form on secure servers of our Payment Processors. The Payment Processors’ use of
your Personal Information is governed by their respective privacy policies which may or may not
contain privacy protections as protective as this Policy. We suggest that you review their
respective privacy policies.
You are able to delete certain Personal Information we have about you. The Personal Information
you can delete may change as the Website and Services change. When you delete Personal
Information, however, we may maintain a copy of the unrevised Personal Information in our
records for the duration necessary to comply with our obligations to our affiliates and
partners, and for the purposes described below. If you would like to delete your Personal
Information or permanently delete your account, you can do so by contacting us.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any
Service you have requested, we may share your information with our affiliates, contracted
companies, and service providers (collectively, “Service Providers”) we rely upon to assist in
the operation of the Website and Services available to you and whose privacy policies are
consistent with ours or who agree to abide by our policies with respect to Personal Information.
We will not share any personally identifiable information with third parties and will not share
any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to
perform services on our behalf or comply with legal requirements. Service Providers are given
the information they need only in order to perform their designated functions, and we do not
authorize them to use or disclose any of the provided information for their own marketing or
We may also disclose any Personal Information we collect, use or receive if required or
permitted by law, such as to comply with a subpoena or similar legal process, and when we
believe in good faith that disclosure is necessary to protect our rights, protect your safety or
the safety of others, investigate fraud, or respond to a government request.
Retention of information
We will retain and use your Personal Information for the period necessary until the purchase
order or Services are fulfilled, to enforce our agreements, resolve disputes, and unless a
longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you
update or delete it, but not in a manner that would identify you personally. Once the retention
period expires, Personal Information shall be deleted. Therefore, the right to access, the right
to erasure, the right to rectification, and the right to data portability cannot be enforced
after the expiration of the retention period.
Transfer of information
Depending on your location, data transfers may involve transferring and storing your information
in a country other than your own. However, this will not include countries outside the European
Union and European Economic Area. If any such transfer takes place, you can find out more by
checking the relevant sections of this Policy or inquire with us using the information provided
in the contact section.
Data protection rights under the GDPR
If you are a resident of the European Economic Area (“EEA”), you have certain data protection
rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the
use of your Personal Information. If you wish to be informed what Personal Information we hold
about you and if you want it to be removed from our systems, please contact us. In certain
circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously given your consent to the
processing of your Personal Information. 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.
(ii) You have the right to learn if your Personal Information is being processed by us, obtain
disclosure regarding certain aspects of the processing, and obtain a copy of your Personal
Information undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated
or corrected. You also have the right to request us to complete the Personal Information you
believe is incomplete.
(iv) You have the right to object to the processing of your information if the processing is
carried out on a legal basis other than consent. Where Personal Information is processed for the
public interest, in the exercise of an official authority vested in us, or for the purposes of
the legitimate interests pursued by us, you may object to such processing by providing a ground
related to your particular situation to justify the objection.
(v) You have the right, under certain circumstances, to restrict the processing of your Personal
Information. These circumstances include: the accuracy of your Personal Information is contested
by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure
of your Personal Information and request the restriction of its use instead; we no longer need
your Personal Information for the purposes of processing, but you require it to establish,
exercise or defend your legal claims; you have objected to processing pending the verification
of whether our legitimate grounds override your legitimate grounds. Where processing has been
restricted, such Personal Information will be marked accordingly and, with the exception of
storage, will be processed only with your consent or for the establishment, to 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.
(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal
Information from us. These circumstances include: the Personal Information is no longer
necessary in relation to the purposes for which it was 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 such as where processing is necessary: for exercising the right of freedom of expression
and information; for compliance with a legal obligation; or for the establishment, to exercise
or defense of legal claims.
(vii) You have the right to receive your Personal Information that you have provided to us in a
structured, commonly used, and machine-readable format and, if technically feasible, to have it
transmitted to another controller without any hindrance from us, provided that such transmission
does not adversely affect the rights and freedoms of others.
(viii) You have the right to complain to a data protection authority about our collection and
use of your Personal Information. If you are not satisfied with the outcome of your complaint
directly with us, you have the right to lodge a complaint with your local data protection
authority. For more information, please contact your local data protection authority in the EEA.
This provision is applicable provided that your Personal Information is processed by automated
means and that the processing is based on your consent, on a contract which you are part of, or
on pre-contractual obligations thereof.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details provided
in this document. Please note that we may ask you to verify your identity before responding to
such requests. Your request must provide sufficient information that allows us to verify that
you are the person you are claiming to be or that you are the authorized representative of such
person. If we receive your request from an authorized representative, we may request evidence
that you have provided such an authorized representative with power of attorney or that the
authorized representative otherwise has valid written authority to submit requests on your
You must include sufficient details to allow us to properly understand the request and respond
to it. We cannot respond to your request or provide you with Personal Information unless we
first verify your identity or authority to make such a request and confirm that the Personal
Information relates to you.
Our Website and Services use “cookies” to help personalize your online experience. A cookie is a
text file that is placed on your hard disk by a web page server. Cookies cannot be used to run
programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only
be read by a web server in the domain that issued the cookie to you. You may learn more about
cookies and how they work here.
and for statistical purposes. Please note that you have the ability to accept or decline
cookies. Most web browsers automatically accept cookies by default, but you can modify your
browser settings to decline cookies if you prefer.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do
not want to have your online activity tracked. Tracking is not the same as using or collecting
information in connection with a website. For these purposes, tracking refers to collecting
personally identifiable information from consumers who use or visit a website or online service
as they move across different websites over time. How browsers communicate the Do Not Track
signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret
or respond to Do Not Track signals communicated by your browser. Even so, as described in more
detail throughout this Policy, we limit our use and collection of your Personal Information.
Social media features
Our Website and Services may include social media features, such as the Facebook and Twitter
buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social Media
Features may collect your IP address, what page you are visiting on our Website and Services,
and may set a cookie to enable Social Media Features to function properly. Social Media Features
are hosted either by their respective providers or directly on our Website and Services. Your
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are
committed to keeping your e-mail address confidential and will not disclose your email address
to any third parties except as allowed in the information use and processing section or for the
purposes of utilizing a third-party provider to send such emails. We will maintain the
information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail
is from and provide clear information on how to contact the sender. You may choose to stop
receiving our newsletter or marketing emails by following the unsubscribe instructions included
in these emails or by contacting us. However, you will continue to receive essential
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by
us. Please be aware that we are not responsible for the privacy practices of such other
resources or third parties. We encourage you to be aware when you leave the Website and Services
and to read the privacy statements of each and every resource that may collect Personal
We secure information you provide on computer servers in a controlled, secure environment,
protected from unauthorized access, use, or disclosure. We maintain reasonable administrative,
technical, and physical safeguards in an effort to protect against unauthorized access, use,
modification, and disclosure of Personal Information in our control and custody. However, no
data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there
are security and privacy limitations of the Internet which are beyond our control; (ii) the
security, integrity, and privacy of any and all information and data exchanged between you and
the Website and Services cannot be guaranteed; and (iii) any such information and data may be
viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use to
communicate with us and the security you use to protect your credentials, please take
appropriate measures to protect this information.
In the event we become aware that the security of the Website and Services has been compromised
or Users’ Personal Information has been disclosed to unrelated third parties as a result of
external activity, including, but not limited to, security attacks or fraud, we reserve the
right to take reasonably appropriate measures, including, but not limited to, investigation and
reporting, as well as notification to and cooperation with law enforcement authorities. In the
event of a data breach, we will make reasonable efforts to notify affected individuals if we
believe that there is a reasonable risk of harm to the User as a result of the breach or if
notice is otherwise required by law. When we do, we will post a notice on the Website, send you
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at
any time at our discretion. When we do, we will revise the updated date at the bottom of this
page. We may also provide notice to you in other ways at our discretion, such as through the
contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised
Policy unless otherwise specified. Your continued use of the Website and Services after the
effective date of the revised Policy (or such other act specified at that time) will constitute
your consent to those changes. However, we will not, without your consent, use your Personal
Information in a manner materially different than what was stated at the time your Personal
Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By
accessing and using the Website and Services and submitting your information you agree to be
bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not
authorized to access or use the Website and Services.
If you have any questions, concerns, or complaints regarding this Policy, the information we
hold about you, or if you wish to exercise your rights, we encourage you to contact us using the
We will attempt to resolve complaints and disputes and make every reasonable effort to honor
your wish to exercise your rights as quickly as possible and in any event, within the timescales
provided by applicable data protection laws.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar
https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the
public in the context of your comment.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies.
This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display
choices. Login cookies last for two days, and screen options cookies last for a year. If you select
“Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies
will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes
no personal data and simply indicates the post ID of the article you just edited. It expires after 1
your interaction with that embedded content, including tracking your interaction with the embedded
content if you have an account and are logged in to that website.
For users that register on our website (if any), we also store the personal information they provide in their
user profile. All users can see, edit, or delete their personal information at any time (except they
cannot change their username). Website administrators can also see and edit that information.