Your privacy is critically important to us. At Shane Irving Pty Ltd, 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 aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
• 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.

Who We Are and What This Policy Covers

Howdy! We are the folks behind a variety of products and services designed to allow anyone — first responders, servicemen & women and law enforcement communities, small business owners, and enterprises — to explore, learn, connect and thrive in their personal & professional lives. We are committed to the protection of your privacy. Our aim is to provide an online environment that will ensure the information you provide to us, is handled in a secure, efficient and confidential manner.

This Privacy Policy applies to information that we collect about you when you use:

• Our websites (including shaneirving.com, ops.live, vowelcode.com, officerstrong.com, myrituals.com.au);
• Our other Shane Irving Pty Ltd products, services, and features that are available on or through our websites;

Throughout this Privacy Policy we’ll refer to Shane Irving Pty Ltd as “Shane Irving”

This Privacy Policy also applies to information we collect when you apply for a job at Shane Irving.

Throughout this Privacy Policy we’ll refer to our websites, mobile applications, and other products and services collectively as “Services.”

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, 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, and from outside sources. 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 your account. For example, we require individuals who sign up for an officerstrong.com account to provide an email address and password, along with a username or name — and that’s it. You may provide us with more information — like your address and other information you want to share — but we don’t require that information to create a officerstrong.com account.
• Public profile information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a officerstrong.com account, your username is part of that public profile, along with any other information you put into your public profile, like a photo or an “About Me” description. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
• Payment and contact information: If you buy something from us or earn revenue through your site, we’ll collect information to process those payments and contact you. If you buy something from us — a subscription to a officerstrong.com plan, some Officer Strong swag, you’ll provide additional personal and payment information like your name, credit card information, and contact information. We also keep a record of the purchases you’ve made. If you use our Ecommerce Services, you’ll have to create an account or connect an existing account.
• 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 (hi there!): You may also provide us with information when you respond to surveys, communicate with our staff about a support question, post a question in our public forums, or sign up for a newsletter like the one we send through Officer Strong. When you communicate with us via form, email, phone, officerstrong.com comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
• Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online services, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services — for example, when you create or make changes to your profile on officerstrong.com.
• Usage information: We collect information about your usage of our Services. 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: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
• Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a really amazing photograph of the sunrise to your website.
• Interactions with other users’ sites: We collect some information about your interactions with other users’ sites while you are logged in to your account with us, such as your “Likes” and the fact that you commented on a particular post, so that we can, for example, recommend posts we think may interest you.
• Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Shane Irving uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads.

Information We Collect from Other Sources

We may also get information about you from other sources. For example, if you create or log in to your officerstrong.com account through another service (like Google) or if you connect your website or account to a social media service (like Twitter), we’ll receive information from that service (e.g., your username, basic profile information, friends list) via the authorization procedures for that service.

Third-party services may also give us information, like mailing addresses for individuals who are not yet our users (but we hope will be!). We use this information for marketing purposes like postcards and other mailers advertising our Services.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. For example, to set up and maintain your account, provide customer service, process payments and orders, and verify user information.
• To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, 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 market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a paid plan after receiving a marketing message), and understanding and forecasting user retention.
• 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 Shane Irving 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 customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services, recommending content through our Reader post suggestions, and providing new essays and stories through Officer Strong for your reading pleasure.
• 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 Shane Irving; texting you to verify your payment; or calling you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
• To recruit and hire new Shane Irvingians. For example, by evaluating job applicants and communicating with them.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU 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; 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; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or

(5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on 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 WooCommerce Payments, payment providers that process your credit and debit card information, payment providers you use for your own ecommerce operations, 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); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); 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); other third-party tools that help us manage operations; and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies.
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request. For more information on how we respond to requests for information about officerstrong.com users.
• 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 Shane Irving, 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 Shane Irving 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. For example, we may share your information with third parties when you authorize us to do so, like when you connected your site to a social media service.
• 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 the use of our Services, 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 in order to clarify or respond to your request, or to help us support other users.

We have a long-standing policy that 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 show ads on some of our our sites, and the revenue they generate lets us offer free access to some of our Services so that money doesn’t become an obstacle to having a voice.

Under a new California law, the California Consumer Privacy Act (“CCPA”), some personalized advertising you see online and on our services might be considered a “sale” even though we don’t share information that identifies you personally, like your name or email address, as part of our advertising program.

Information Shared Publicly

Information that you choose to make public is — you guessed it — disclosed publicly.

That means information like your public profile, posts, other content that you make public, and your “Likes” and comments on our websites are all available to others — and we hope they get a lot of views!

For example, the photo that you upload to your public profile, or a default image if you haven’t uploaded one, is your Globally Recognized Avatar, or Gravatar — get it? 🙂 Your Gravatar, along with other public profile information, displays alongside the comments and “Likes” that you make on other users’ websites while logged in to your officerstrong.com account. Your Gravatar and public profile information may also display with your comments, “Likes,” and other interactions on websites that use our Gravatar service, if the email address associated with your account is the same email address you use on the other website.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.

For example, we keep the web server logs that record information about a visitor to one of Shane Irving’s websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Shane Irving’s websites and investigate issues if something goes wrong on one of our websites.

As another example, when you delete a post, page, or comment from your officerstrong.com site, it stays in your Trash folder for thirty days in case you change your mind and would like to restore that content, because starting from scratch is no fun. After the thirty days are up, the deleted content may remain on our backups and caches until purged.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

• 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, premium programs that carry an additional charge — may not be accessible.
• Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs.
• Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
• Set your browser to reject cookies: At this time, Shane Irving does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Shane Irving’s websites, with the drawback that certain features of Shane Irving’s websites may not function properly without the aid of cookies.
• Opt out of our internal analytics program: You can do this through your user settings. By opting out, you will stop sharing information with our analytics tool about events or actions that happen after the opt-out, while you’re logged in to your officerstrong.com account. For more information, please see our Cookie Policy.
• 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. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

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”), 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)

If you are located in a country that falls under the scope of the GDPR, 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.

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 collected the following categories of personal information from California residents, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);
• Commercial information (your billing information and purchase history, for example);
• Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
• Internet or other electronic network activity information;
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Professional or employment-related information (for example, your company and team information, or information you provide in a job application); and
• Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect in the Information We Collect section above.

We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section.

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.

The CCPA & Personalized Advertising in Our Ads Program

Our mission is to democratize publishing and commerce, and that means making our Services accessible to as many people as possible. We show ads on some of our sites, and the revenue these ads generate lets us offer free access to some of our Services so that money doesn’t become an obstacle to having a voice. As part of our advertising program, we do use cookies to share certain device identifiers and information about your browsing activities with our advertising partners, and those advertising partners may use that information to show you personalized ads on some of our sites.

The personal information we share includes online identifiers; internet or other network or device activity (such as cookie information, other device identifiers, and IP address); and geolocation data (approximate location information from your IP address). These disclosures may be considered a “sale” of information under the CCPA. We do not sell (or share) information through our ads program that identifies you personally, like your name or contact information.

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, scroll down to “How to Reach Us” to, well, find out how to reach us.

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.

Controllers and Responsible Companies

Shane Irving’s Services are worldwide. Different Shane Irving companies are the controller (or co-controller) of personal information, which means that they are the company responsible for processing that information, based on the particular service and the location of the individual using our Services.

Depending on the Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is the Shane Irving company that entered into the contract with you under the Terms of Service for the product or service you use. In addition, Shane Irving Pty Ltd., our Australia-based company, is the controller for some of the processing activities across all of our Services worldwide.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us through our web form or via email. These are the fastest ways to get a response to your inquiry.

Other Things You Should Know (Keep Reading!)

Transferring Information

Because Shane Irving’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

• In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
• In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads and Analytics Services Provided by Others

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver ads that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by Shane Irving and does not cover the collection of information by any third-party advertisers or analytics providers.

Privacy Policy Changes

Although most changes are likely to be minor, Shane Irving may change its Privacy Policy from time to time. Shane Irving encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (like adding a statement to our homepage or the Blog, or sending you a notification through email or your dashboard). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy