A: Privacy Policy and Your Privacy Rights

This Privacy Policy is part of our Terms of Use, which is a legally binding agreement between you and us. To use our site and other parts of our service, both of the following statements must be true:

1. You are not unable to enter into legally binding Agreements due to being under the minimum legal age of adulthood and/or for any other reason(s): and
2. You are not a citizen of, and/or are not accessing this site from, any area outside of the United States of America that nullifies, voids, has laws incompatible with, or in any way enables you not to be bound by, even one of the terms in the Terms of Use.

If even one of the above statements is not true for you, you are forbidden to use SkinnyWalletFatWallet.com and any other part of our service. However, not using our service will not disadvantage you, since content and service equal to or greater than what we provide is available elsewhere on the internet. As for personal opinions and details of personal experiences, there’s a wealth of both on the internet.

If even one of the above statements is not true for you, you must close this page now, not return to SkinnyWalletFatWallet.com and refrain from using any other part of our service until such time (if ever) as both of the numbered statements above are true for you.


Last Edited / Last Revised on Monday, October 26, 2020
In Effect as of Monday, November 2, 2020
Edits / Revisions are not retroactive from the date they go into effect.

Minor editing for clarity. No substantial changes.

The sections of this Privacy Policy

1. Introduction
2. Definitions
3. Incorporated by reference
4. Changes to our Privacy Policy
5. Your privacy rights: we’ve got you covered.
6. External Links (about our use of)
7. What data we collect
8. We protect your PII (personally identifiable information)
9. What we use your data for
10. When we share your data
11. Why we use third-party service providers
12. Collection, transfer, processing & storage of PII in other countries
13. Disclosure Request: about third parties and our use and sharing of your data
14. Disclosure Request: accessing and managing your PII
15. Your agreement
16. A note about “Contests and Giveaways: Rules and Conditions”


1. Introduction
Welcome to Skinny Wallet Fat Wallet. Our website address (URL) is SkinnyWalletFatWallet.com.

We take great pride in the relationship of trust we’re building with each of our users and look forward to strengthening and deepening those relationships throughout the years to come. We’re dedicated to treating your personal information with care and respect and our Privacy Policy lays out exactly how we do that.


2. Definitions

  • Internet Protocol (IP) address: a unique numeric or alphanumeric identifier for each computer or device on the Internet
  • linked PII (personally identifiable information): information linked to a specific person, which makes it possible to identify or locate that person, such as full name, postal or email address, Social Security number, actual age or date of birth, etc.
  • linkable PII: information such as an IP address, which could be linked to a specific person
  • non-PII:* information that isn’t linked to a specific person or device (i.e. anonymous data), such as age range or gender; country, state or zip code
  • data: linked and linkable PII and any non-PII that’s been combined with either linked or linkable PII

* Much to our annoyance, information we’ve always considered linkable PII, such as device IDs and IP addresses has legally been classified as non-PII for years.

If any entity with deep pockets has the identifying information for your computer or devices, how hard would it be for them to get your name, physical address and goodness knows what else? That’s why we’ve been so annoyed by what we consider a gross misclassification.

Update: in early 2017, we became aware that both the U.S.A.’s Federal Trade Commission (FTC) and the EU are working on shifting that type of information from non-PII to either linkable or linked PII. Hooray for progress!


3. Incorporated by reference
Along with “Copyright Policy & Infringement Claims and Counterclaims”, “FTC Compliance Notice”, “Earnings Disclosure and Disclaimer”, and “Comment Policy & Rules,” this Privacy Policy, including the supplemental information provided in: “How We Use Cookies and Similar Technology,” is an important part of our Terms of Use and is incorporated by reference.

“How We Use Cookies and Similar Technology” is a vital supplement to this Privacy Policy. It lists every third-party service we use (and the contact information for each) and goes into great detail about how you can control what information about you can and can’t be collected.


4. Changes to our Privacy Policy
Occasionally, we’ll need to revise this Privacy Policy. If any of the revisions substantially affect how we handle your PII, we’ll do one or both of the following:

1. update the “Last Edited / Revised” and “In Effect as of” dates on our Privacy Policy and put a notice on our site with a link to the revised Privacy Policy; or
2. update the “Last Edited / Revised” and “In Effect as of” dates on our Privacy Policy and, if you’ve given us your email address, send you email notification of the revision(s).

You agree that we are not responsible for emails that can not be delivered due to an invalid email address, nor for emails that remain unread for any reason, including your email settings sending our email to the spam folder.

So that our users don’t come under new or different terms without warning, the “In Effect as of” date will always be at least seven calendar days after the revision(s).

You agree it’s your responsibility to check for changes to the Privacy Policy of any site you visit and that, therefore, you agree that continuing to use SkinnyWalletFatWallet.com or any other part of our service on or after the “In Effect as of” date of any changes to our Privacy Policy constitutes your agreement to abide by and be bound by that version of our Privacy Policy.


5. Your privacy rights: we’ve got you covered.
SkinnyWalletFatWallet.com was the very first website to voluntarily give all its visitors equal privacy rights and protections.

On our site everyone, not just California residents, gets the rights and protections guaranteed by the California Online Privacy Protection Act (CalOPPA) and by “Shine the Light” (California Civil Code Section 1798.83).

Everyone also gets the rights and protections guaranteed by;

  • the EU’s General Data Protection Regulation (GDPR);
  • the UK’s Data Protection Act 1998 (DPA); and
  • other privacy laws from around the world.

Ours is also the first site whose owners can truthfully say all of the following;

  • When we encountered a law with language only a lawyer could love, we “translated” it to plain language before using it in our Privacy Policy.
  • When we found rights we considered weak, we strengthened them before adding them to our Privacy Policy.
  • And, when we felt a right couldn’t be enjoyed without overly-burdensome action from the people it was designed to protect, we greatly simplified the process and made it much easier and faster.

The unavoidable side effect of doing all these things is that it made this page very long. We can’t overemphasize how much we respect your time: we know it’s the most valuable asset you’ll ever have. It’s our hope the disclosures we make in our Privacy Policy and its supplemental page: “How We Use Cookies and Similar Technology” will prompt readers to consider the value of those disclosures and whether or not they’d like to see them on other, possibly all, websites.


6. External Links
We frequently provide links to content and services located on other websites (“third-party websites”). If you choose to visit a third-party website, you will be governed by its Privacy Policy and Terms Of Use while there. That includes any social site(s) you communicate with us on.

We have no control over, and therefore disavow all legal and other responsibility for, the opinions expressed; completeness, design, content, suitability, usability, accuracy, practices, or conditions of; and everything else on and related to, third-party websites.

We’ve visited every site we link to on SkinnyWalletFatWallet.com and have read their Privacy Policies and Terms of Use. We like these sites and feel comfortable on them.  However, your own comfort level could be very different from ours, or ours could be based on assumptions or opinions formed on faulty, incomplete, missing, or out-of-date information. If you visit any of these sites, you expressly agree that you do so at your own risk.

We strongly recommend familiarizing yourself with the Privacy Policy and Terms Of Use of every website you visit, especially those you interact with and certainly those you share your PII with.


7. What data we collect

  • information you voluntarily give us when you contact us, leave a comment, enter a contest or giveaway, participate in a poll or survey, interact with us on a social networking (or other) site, or give us by any other means;
  • information automatically collected when you visit SkinnyWalletFatWallet.com;* and
  • information provided by third party services on and off our site.

8. We protect your PII
We take the security of all PII very seriously. The padlock icon to the left of our URL (at the top of every page) shows we have Secure Sockets Layer (SSL) security on our site. That means SkinnyWalletFatWallet.com has been verified as a legitimate site and that all information sent between your web browser and our site is encrypted.

In addition to using SSL security on our site, we take a number of commercially reasonable administrative, technical, personnel and physical steps to safeguard information in our possession from loss, theft and unauthorized access, use or disclosure, and accidental or malicious disclosure or modification.

Despite the lengths we go to to protect the security of PII, no method of transmission can be guaranteed to be 100% error-free and no method of transmission, or method of storage, or location on earth is 100% secure. Therefore, we cannot and do not guarantee the absolute accuracy or security of PII.


9. What we use your data for

  • to communicate with you on our site and elsewhere; and
  • to send you a “welcome” email and, if you allow, additional emails* including but not limited to promotions, offers, notices of events, invitations to participate in polls or surveys, and more; and
  • to send you items or information you’ve requested from us or to carry out any other requests you’ve made of us if it’s possible for us to do so; and
  • (if these activities become available) to send you items you’ve won in contests and giveaways; and
  • to analyze the use of; and to manage, deliver, administer, and improve, our website, content, recommendations, and other parts of our service; and
  • for detection and prevention of illegal activity and to protect the security of our users, our service, ourselves, and the parties that make it possible for us to provide our service; and
  • to ensure legal or regulatory compliance.

* If you give us your email address, you explicitly and willingly agree to receive a welcome email from us. You understand you can opt out of receiving further emails from us at any time by following the instructions at the bottom of every email we send, including the welcome email. (We love staying in touch, but have no desire to go where we’re not welcome).


10. When we share your data
It’s our intention to build at least one more business by late-2022. If we do, we’ll update this page with the name(s) of our additional business(es). We’ll share non-PII and PII about our users between our businesses if doing so will help us improve or expand the service(s) we provide, or enhance the functioning of our business(es).

We do not sell, rent or trade your PII. However, in the event that SkinnyWalletFatWallet.com is ever sold or transferred, in part or in full, changes ownership, or becomes part of a merger or acquisition, PII is legally considered to be a business asset and, as such, will transfer to the new owner(s).

Barring an unforeseen or unavoidable event that prevents us from doing so, we will send notifications to all affected parties for which we have email addresses and post a notice on this page before PII becomes subject to a different privacy policy.

We may quote or use screen shots (or similar media) of comments you make anywhere to or about us, or about any of our content, services or materials. If you include PII in your comments, you hereby grant us permission to republish it on or off of SkinnyWalletFatWallet.com.

We may quote or use screen shots (or similar media) of emails, or sections of emails, but we’ll only include your real name if you give us permission to do so and we’ll never include your email address.

We may quote or use screen shots (or similar media) of reviews, or sections of reviews you write about us, our service or any part of our service.

We may share information, including PII, which you have made publicly available.

If necessary to comply with state, federal or international laws or international agreements; to assist in the investigation of possible criminal activity; or to report what we believe to be illegal activity, we will share your information with the appropriate legal authorities, even if that authority is in a country that is not a participant in an international agreement with your own. Should it become necessary for us to share your data with a legal authority, we may be legally barred from alerting you or have other cause not to alert you that we have done so.

By remaining on this site, you give us your express permission to share  your data, including your PII, in any or all of the ways stated above.


11. Third-party service providers: what data they collect and why we use them
All parts of our service depend, in part or in whole, on third-party service providers. Without them, we wouldn’t be able to provide our service.

We interact only with third-party service providers that are well-known in their fields and have built a solid reputation in regard to their use and protection of PII.

Third-party services we always use;

CMS
A website must be built with something and that “something” is called a “content management system” (CMS). The one we use is WordPress and here’s their Privacy Policy. They don’t publish an address or phone number, but here’s their Contact page.

Comment Platform
We love(!) interacting with our visitors and having areas where our visitors can leave comments makes that easy.

Currently, we use the WordPress comment platform. If that changes, we’ll let you know here. We linked to the WordPress Privacy Policy and contact information above, in “CMS”.

When submitting comments, you can use aliases/nicknames and information that completely hides your identity. We do not verify information entered nor do we require verification.

To help minimize spam comments, we require everyone to fill in an email address and a name or nickname before s/he can submit a comment. Your comment and the name/nickname/username you use will be publicly-viewable. Unless we believe it would be objectionable to too many of our regular visitors, the image (“avatar”) you use when submitting your comment will also be publicly-viewable. If given a field to enter the address of your website, that information may or may not be publicly-viewable, at our discretion. The address you enter in the email address field will not be publicly-viewable.

When a comment is submitted, the relevant details (comment, username, email, website address) you provide are visible to and stored by us and the comment platform (WordPress). These details are stored so that your comments can be displayed back to you, and to anyone viewing the comment sections on the site.

We, and the WordPress comment platform, also collect and store your IP address and browser user agent string (UA) to help detect spam comments and quickly identify viewability problems and other issues. UA can also be used to customize this site’s behavior or content to specific browser versions.

Internet Protocol (IP) address: a unique numeric or alphanumeric identifier for each computer or device on the internet

A browser user agent string is a line of code automatically sent by your browser to every website it visits. It identifies which type of device is being used (phone, computer, tablet, etc.,) which browser is being used, what version of the browser, and on which operating system.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service (Gravatar) to see if you are using it. Gravatar is owned by Automattic.
Automattic’s Privacy Policy: https://automattic.com/privacy/
Automattic’s contact page: https://automattic.com/contact/

An email hash converts your email address into a 32, 40 or 64-character code. Each email address has a unique email hash which remains persistent across all devices, apps and browsers. This code cannot be reversed back into an email address which means anyone who doesn’t have your email address will not be able to get it from your email hash.

Email hashes are anonymized identifiers that cannot reveal any personally identifiable information.

Gravatar stands for “globally recognized avatar”. An avatar is an image you use to represent yourself online. It’s the small image that appears by your name when you leave a comment. A Gravatar is an avatar which was custom-made by the user.

It isn’t necessary to have a Gravatar in order to leave a comment, nor is it necessary to use your Gravatar if you do have one. In either case, a default avatar would appear beside your name.

Google Analytics
Google Analytics is a program that lets us understand and analyze visitor traffic. It collects, and shares with us, non-PII information such as visitors’ location (country, state and possibly city and/or zip code), gender, age range (i.e. 20-30 instead of 24); what web page a visitor was on immediately before coming to our site and what page s/he goes to immediately after; and which of our pages s/he visited and how long s/he stayed on each.

With this information, we can get a clear picture of what our visitors do and don’t want. That helps us cater to them and provide more of the content they’re interested in. The Google Analytics program makes no effort to discover the personal identities of visitors to our site.

What information Google Analytics can collect and how Google can use it is limited by the Google Analytics Terms of Service and the Google Privacy Policy.

SkinnyWalletFatWallet.com abides by Google’s policies.

You may also be interested in the following two links: How Google uses data when you use our partners’ sites or apps  and Safeguarding your data (Google Analytics)

If you would like to prevent Google from using Google Analytics to collect information about you, you can use the Google Analytics Opt-out Browser Add-on. (Works with Internet Explorer, Chrome, Firefox, Safari, and Opera.)

NOTICE: Using the “Google Analytics Opt-out Browser Add-on” does NOT prevent Google from using its other tools and technologies to track you and collect this (and much more) information about you for its own use. It merely tells Google not to share this portion of their collected data with website owners.

Google Inc.
1600 Amphitheatre Parkway
Mountain View, CA 94043 USA
Phone: +1 650-253-0000

Contact information for Google offices around the world

Third-party services we’re considering using;

Email Management System (EMS)
This is a program we’ll definitely use – as soon as we find one we trust, based on the company having built a solid reputation for trustworthiness and dependability over several years. We will use the EMS to manage the emails we send to our users who want them and, should our users ever want us to create a newsletter for them, we will use the EMS to manage that as well.

Typical data gathered and stored by an EMS and us would be any PII and non-PII you give us, plus statistical data regarding email opening and clicks. If you choose to receive emails and/or a newsletter from us, this data is used to;

  • allow the EMS to send you that content,
  • manage our contact list,
  • contact you if we need to obtain or provide additional information, and
  • monitor and improve our emails and newsletter.

Once we choose an EMS, we will provide their contact information and a link to their Privacy Policy here.

You will be able to unsubscribe from our emails and/or newsletter at any time by clicking the unsubscribe link at the bottom of any of our emails or our newsletter.

YouTube Videos (embedded)
Google owns YouTube and what information they collect is in their Privacy Policy, which we linked to above, in: “Google Analytics.”

Google Analytics Display Advertiser Features
We don’t know what any of this stuff is, but we think it’s ways for website owners to earn ad revenue through Google Analytics(?) If we ever decide we need to do that, we’ll do some research, tell you what we find out and link to the appropriate Privacy Policy/Policies (if there are any in addition to the one we linked to above, in: “Google Analytics”).

Remarketing with Google Analytics
Google Display Network Impression Reporting
DoubleClick Platform integrations
Google Analytics Demographics and Interest Reporting

Google AdWords
If we ever become advertisers through Google AdWords, we’ll adhere to their AdWords Policies (and we’ll edit this page to let you know).

A link shortener
We’re still researching options and figuring out if we have a need for this. We’re currently looking at Bitly and Pretty Links, but don’t yet know which, if either, we’ll use.

A plugin to add buttons for social networking sites
We know nothing (about this technology), John Snow. We’ll add a plugin for this eventually. When we do, this is where we’ll let you know about it.

An RSS feed
More technology we don’t, yet, know anything about. If we ever decide to add this feature, we’ll tell you about it here.


Third-party services we used during the prior calendar year

We used the third-party services listed above, under the heading: “Third-party services we always use”. If we used any other third-party services in the previous calendar year, we’ll list them here, along with contact information and a link to the Privacy Policy of each.

[We used no other third-party services during the prior calendar year.]


12. Collection, transfer, processing & storage of PII in other countries
We (the owners of Skinny Wallet Fat Wallet) are located in the U.S.A. SkinnyWalletFatWallet.com is located on a server in the U.S.A. The owners of the server live in and operate their business in Canada. Some of our third-party providers may be located elsewhere.

We store all of the data we have on computers and in physical files, in our office, in the U.S.A. The person in charge of managing and protecting that data (our “data controller”) is Sharon Lewis. For matters regarding PII, you can reach her via this Contact Form.

Once data is no longer needed for its original purpose(s) and there’s no legal justification or requirement, or legitimate business purpose for keeping it, we destroy it and dispose of it.

By remaining on or returning to our site, you give your EXPRESS and informed consent to the collection, transfer, processing and storage of information related to you and/or your use of our service, including, possibly, your PII, as we have described those actions.

By remaining on or returning to our site, you give your EXPRESS and informed consent to the collection, transfer, processing and storage of information related to you and/or your use of our service, including, possibly, your PII, in and to countries outside of your own – including, possibly, countries that are not participants in an international agreement with your own country – and you understand your information will be subject to privacy laws that are different from, and may be stronger or weaker than, those in your country.


13. Disclosure Request: about third parties and our use and sharing of your data
Residents of some countries (and all the legitimate users of our site, because we love you guys) have the right, once per calendar year, to ask us:
1. what categories of their PII we shared with third parties during the previous calendar year;
2. what the names of the third parties are and, if not obvious from their names, what their primary services or products are; and
3. what the contact information is for each.

Instead of requiring you to contact us for this information and making you wait a year between requests – just to find out what we did the previous year – we’ve made the information publicly available in our Privacy Policy. We keep it up-to-date and you can read it any time you like. You will find it above, in section 11: “Third-party service providers: what data they collect and why we use them” and “Third-party services we used during the prior calendar year”.

We realize publicly disclosing which third party services we use gives our competitors wide-open, unfettered access to a big chunk of our business model, but we care about your peace of mind much more than we worry about whatever our competitors might copy from our business model.

If, during or after reading our Privacy Policy, you’re uncomfortable with anything regarding the way we collect or handle your data, please leave SkinnyWalletFatWallet.com and do not use any other part of our service until such time (if ever,) as you feel you can trust us.

By remaining on or returning to SkinnyWalletFatWallet.com, or by using any other part of our service, you explicitly agree that you understand you are giving us your EXPRESS permission to collect and use your data, including your PII, as detailed in our Privacy Policy and in: “How We Use Cookies and Similar Technology”.

Note: We only collect as much data as we need to make our service function optimally and we only share as much data with third parties as they need for that same purpose. Without this data, our service won’t function. Therefore, our service won’t be available to you. We sincerely hate to lose you, but we’d rather lose users than have them stay, despite being upset by our use of their data.


14. Disclosure Request: accessing and managing your PII
If you’d like to know what, if any, personally identifiable information (PII) we have about you, contact us via the Contact Form to find out how to make a Disclosure Request. Before we can disclose to you whether or not we have any PII about you, we are, for security and legal reasons, required to have you verify your identity. Likely, we will have you verify your identity by sending us a legible scan or photo of your valid, non-expired driver’s license or state-issued photo ID card though we may, at our discretion, choose to use different or additional verification methods.

After we’ve sent any PII we have – if we have any – you have the right to correct, update or amend it, or to ask us to delete/destroy any of it we have no legal or business purpose for keeping. If you wish to have us do any of these things, you must make us aware of that within 30 calendar days after receiving our reply to your Disclosure Request.

Be aware that fulfilling Disclosure Requests and correcting, updating, amending, or deleting/destroying PII on request takes considerable time. Therefore, we must charge a fee for each service.

We don’t delete all types of personal information. We keep copies of all correspondence between us and our legitimate users and all other data we have legal reason, obligation or permission to keep. We also keep, in a dedicated file, all the information we have on users we’ve had to ban or block. Also, to prevent accidental or malicious deletion, information scheduled for deletion may be kept in a dedicated file until we’re certain it was meant to be deleted, and, deleted information may remain on backup systems indefinitely.


15. Your agreement
By using our website or any other part of our service, you UNAMBIGUOUSLY declare your EXPRESS agreement and lack of objection to, the terms in our Terms of Use, including, but not limited to, those in this incorporated Privacy Policy.

Additionally, you affirm that any personal information you submit or share will not be that of any person other than yourself and that any information you submit or share will be truthful, accurate and legal.


16. Contests and Giveaways: Rules and Conditions

It may be as late as mid – late-2022 (or even later) before we’re able to run contests and giveaways, but having them is definitely in our plans. At least a week before we have our first one, we’ll get the Rules and Conditions page done and posted.

For clarity: “Contests and Giveaways: Rules and Conditions” is not yet, and won’t be, incorporated into our Terms of Use until it’s posted and its “In Effect as of” date arrives.

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