1.0 Our core beliefs regarding user privacy and data protection
- User privacy and data protection are human rights
- Data is a liability, it should only be collected and processed when absolutely necessary
- Spam sucks for everyone
- We will never sell, rent or otherwise distribute your personal information
2.0 Relevant legislation
Along with our business, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- California Consumer Privacy Act (CCPA)
- EU General Data Protection Regulation 2018 (GDPR)
- EU-U.S. (2016) and Swiss-U.S. (2017) Privacy Shield Frameworks
- EU Data Protection Directive 1995 (DPD)
- UK Data Protection Act 1988 (DPA)
- Australian Privacy Act 1988 (APA)
This site's compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences' specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.
3.0 Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer's IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
3.2 Persistent Login
To alleviate user frustration with constant requirements to login via email address and an emailed login link (as well as any secondary security enabled for a user account), we offer a persistent login cookie. The cookie is set when checking Remember this Device and successfully logging in. This cryptographically secure cookie contains a unique username and password that enables automatic login for 90 days.
Disabling cookies on your internet browser will disable the ability to Remember this Device.
3.3 Email links
Should you choose to contact us using an email link like this one, none of the data that you supply will be stored by this website. Instead, it will be passed to / be processed by Google Suite, a third party data processors, defined in section 6.0. Our emails are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
3.4 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website's own database or in any of our internal computer systems.
Your email address will remain within MailChimp's database for as long as we continue to use MailChimp's services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you must obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic (no more than once per month) newsletter-style emails from us.
3.5 Transactional emails
For the purposes of account login and site-related email notifications, the email address that you submit to us will be forwarded to SendGrid who provide us with email delivery services. We consider SendGrid to be a third party data processor (see section 6.0 below).
Your email address will only be stored by SendGrid within our account and only for the purposes of email deliverability logs. If you wish to be removed from their systems, you may contact them directly at firstname.lastname@example.org
3.6 Heatmaps and click tracking
For the purposes of improving overall user experience, mouse and keyboard activity may be logged by CrazyEgg or Mouseflow who provide us with heatmap and click tracking services. We consider CrazyEgg and Mouseflow to be third party data processors (see section 6.0 below).
Your session playback and additional data will be stored for a maximum of 90 days. If you wish to pro-actively remove yourself from these services, you may opt-out of Mouseflow or opt-out of CrazyEgg.
3.7 Location data
To help you and others on HeroMuster find players that are nearby, HeroMuster uses your IP address to determine your country and postal code upon account creation and for logging and displaying to you data about any account access attempts such as logging in, failing to enter a correct password, etc.
Only your IP address is passed to IPInfoDB (see section 6.0 below). For postal codes outside of the US, we also use the Google Maps API to retrieve more detailed localization data, such as latitude, longitude, city, state, region, and country. The postal code can be removed from your account to limit localization.
The specific postal code will never be exposed publicly and will not be returned in any searches and will only be used to determine proximity for the searcher.
3.8 Value of personal information
Consistent with California law, if you choose to exercise your applicable CCPA rights, we won't charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.
4.0 How we store your personal information
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
5.0 About this website's server
This website is hosted by Dreamhost within a US data center located near Portland, Oregon.
All traffic (transfer of files) between this website and your browser is encrypted and delivered over HTTPS.
6.0 Our third party data processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All 4 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
7.0 Data Breaches
We will report any unlawful data breach of this website's database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 Data Controller
The data controller of this website is: Slowpreneur Inc, a US S-Corporation with company number: +1.720.310.5687
Whose registered office is:
Broomfield, CO 80038-0030
9.0 Data Protection Officer
CEO, Slowpreneur Inc
- Added CCPA to section 2.0
- Added section 3.8: Value of personal information
- Changed section 3.3
- Email now handled by 3rd party data processor
- Added section 3.7
- Added IPInfoDB to section 6.0
- Added section 3.6
- Added CrazyEgg and Mouseflow to section 6.0