Privacy & Security Policy

Legal & Privacy Statement

1. Introduction

The Good Soldier, LLC (“The Good Soldier”), is committed to maintaining the accuracy, confidentiality and security of your personal information. This Website Privacy Policy describes the personal information that The Good Soldier collects from or about you when you visit our website, and how we use and to whom we disclose that information. The effective date of this Website Privacy policy is June 19, 2018.

2. Application

The Good Soldier is a family of companies with operations both inside and outside of the United States of America.  The Good Soldier has adopted a series of Website Privacy Policies in order to address the specific privacy concerns of certain groupings of individuals and specific regulations covered under the European Union General Data Protection Regulation (GDPR) (EU) 2016/679 and the EU-U.S. Privacy Shield Framework.

3. Organizations Covered by this Policy

This policy includes the parent company, The Good Soldier, LLC and its affiliated entities, including W.Britain, Hudson & Allen Studio, The Art of Don Troiani and The W.Britain Collectors Club, are wholly owned subsidiaries registered and operating under the laws of the United States of America.
All references in this Website Privacy Policy to "The Good Soldier", "we", "us", "our" and like terms should be interpreted accordingly.

4. Policy of Compliance

It is The Good Soldier’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual's right to privacy are different from one jurisdiction to another. This Website Privacy Policy was developed to guide the activities of The Good Soldier. In addition, specific privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions.

The Good Soldier complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  The Good Soldier has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

The Good Soldier also complies with the regulations covered under the European Union General Data Protection Regulation (GDPR) (EU) 2016/679.  Furthermore, The Good Soldier commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources and non-human resources data transferred from the EU. To learn more about GDPR, please visit https://gdpr-info.eu. 

This Website Privacy Policy has a limited scope and application and the rights and obligations contained in this Website Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Website Privacy Policy applies to you, please contact our Privacy Officer for more information.

5. Definitions

5.1 Personal Data

For the purposes of this Website Privacy Policy, personal data is any information relating to an identified or identifiable natural person.  An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (including IP address) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

5.2 Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

5.3 Cookies

Cookies are small pieces of data stored on a User’s device.

5.4 Data Controller

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Website Privacy Policy, we are a Data Controller of your data.

5.5 Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

5.6 Data Subject

Data Subject is any living individual who is the subject of Personal Data.

5.7 User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

6. What Data Do We Collect?

6.1 Personal Data

While using our Service, we may ask you to provide us with personally identifiable information that may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, Country, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

6.2 Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

6.3 Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.

6.4 Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

7. How will this Data be Used?

The Good Soldier uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

8. How Long is your Data Retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, The Good Soldier endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting, tax or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you.

The Good Soldier will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

9. Transfer of Data

We may share your personal information with other parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America, and in some cases, other countries.  Personal data is only transferred by us to another country, including within the The Good Soldier family, if this is required or permitted under the applicable privacy legislation, in particular only in as far as a reasonable level of data protection is assured in the recipient country.

Your consent to this Website Privacy Policy followed by your submission of such information represents your agreement to that transfer.

10. Disclosure Of Data

10.1 Disclosure for Law Enforcement

Under certain circumstances, The Good Soldier may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

10.2 Legal Requirements

The Good Soldier may disclose your Personal Data in the good faith belief that such action is necessary:

• as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of The Good Soldier’s regular reporting activities to other members of the The Good Soldier family (including outside of your home jurisdiction);
• to protect the rights and property of The Good Soldier;
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• where the personal information is publicly available; or
• with your consent where such consent is required by law.

11. How is Your Personal Data Protected?

The Good Soldier endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal data in question. These safeguards are designed to protect your personal data from loss and unauthorized access, copying, use, modification or disclosure.

Moreover, The Good Soldier is being subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and/or the Department of Transportation.

12. Your rights

Under the GDPR and/or Privacy Shield regulations, you have a number of rights with regard to your personal data.

1. You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances the right to data portability.
2. If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
3. You have the right to ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing. 
4. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
5. Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
6. You have the right to lodge a complaint to the relevant authorities if you believe that we have not complied with the requirements of the GDPR and/or Privacy Shield.  In compliance with the Privacy Shield Principles, The Good Soldier commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Privacy Officer at Wbinfo@wbritain.com.
7. You have the right, under certain conditions, to invoke binding arbitration.

13. Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
• For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/  

14. Accountability for Onward Transfer

The Good Soldier only transfers Personal Data to the third-party Service Providers identified in the previous section.  In the event we decide to transfer Personal Data to any other Service Provider, such transfers will be for limited and specified purposes and will take place only if we have notified you in advance and received your consent.  

Personal data is only transferred by us to a third-party Service Provider, only in as far as a reasonable level of data protection is assured by the recipient Service Provider. Where we know a Service Provider is using or disclosing Personal Data in a manner contrary to the Privacy Shield Principles, we will take all reasonable steps to stop and remediate unauthorized processing of Personal Data. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-U.S. Privacy Shield, The Good Soldier is potentially liable.

15. Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

16. Children's Privacy

Our Service does not address anyone under the age of 13 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

17. Changes to this Website Privacy Policy

We may update our Website Privacy Policy from time to time. We will notify you of any changes by posting the new Website Privacy Policy on this page.
If you have provided your email address, we will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Website Privacy Policy.

You are advised to review this Website Privacy Policy periodically for any changes. Changes to this Website Privacy Policy are effective when they are posted on this page.

18. Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Website Privacy Policy and to respond to any questions you may have as to how your data is processed. The contact information for our Privacy Officer is as follows:

WBinfo@wbritain.com   or

Privacy Officer, 10420 Geiser Road, Holland, Ohio, 43528, USA