Data Protection Policy
|Last updated||January 6, 2019|
|The Business||GuerillaStockTrading.com, a licensed business in Clovis, California.|
|GDPR||General Data Protection Regulation.|
|Responsible Person||Lance Jepsen.|
|Database||The website database that stores customer data for The Business.|
1. Data protection principles
The Business is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- Processed lawfully, fairly and in a transparent manner in relation to individuals;
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. General provisions
- This policy applies to all personal data processed by the Business.
- The Responsible Person shall take responsibility for the Business’ ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- This Business is exempt from registering with the Information Commissioner’s Office as an organization that processes personal data per the self-assessment questionnaire on the https://ico.org.uk website. Organisations that do not process personal information on a computer are exempt.
3. Lawful, fair and transparent processing
- Individuals have the right to access their personal data, cancel their subscription, or ask that their account be deleted.
4. Lawful purposes
- All data processed by the Business must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available.
5. Data minimization
- The Business shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, the Business will promptly delete all customers cancelled subscription accounts.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- The Business shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data by anyone other than Lance Jepsen is prohibited. Security is in place to avoid unauthorized sharing of information.
- When personal data is deleted it is done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, the Business shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website) and the FBI.
1. Inventory and document
Stock traders and investors visit this website. Names, email addresses, and passwords are stored for the purpose of access to the Premium section of the website.
a. Hosting & Administration
- Hosting Party
- Inmotion Hosting will only access a database when a trouble ticket is reported. At no time does Inmotion Hosting have access to customer data.
- Managed hosting, external developers and administrators
- Developers are not given access to the admin dashboard where they can access customer information. Developers communicate fixes to Lance Jepsen, who then carries out those fixes. In the event a developer requests admin access as the only way to fix a problem, that developers plugin is removed from the site and the business relationship is terminated. There are no other administrators of the site beyond Lance Jepsen.
- Backup Locations
- Backups are made using a cloud-based backup solution. At no time is the cloud-based backup provider authorized to access customer data.
- Contact forms
- For contact purposes, name and email address are requested on the contact form. An email is sent to Lance Jepsen. That contact information is discarded immediately after the contact email is sent.
- Usernet plugins (Membership, Texting)
- Name, email address, and password are stored for member access in the website database via the membership plugin. The texting plugin stores a members phone number for the purpose of receiving an instant text message if the member opts in for that feature. The texting plugin transmits the customers phone number to Twilio to process the text alert.
- E-commerce (Paypal, Stripe)
- No personal financial information such as credit card numbers, bank account numbers are stored. The Business relies on the external e-commerce processing capabilities of Paypal and Stripe. Physical addresses are irrelevant to the operations of the Business and are not stored.
- Email marketing widgets (e.g. sign up via MailChimp)
- MailChimp is the email provider and only name and email addresses are stored by MailChimp. This information is left on MailChimp servers and not used by The Business.
- Reaction plugins
- Akismet filters spam based on data gathered from users’ comments, email addresses and IP-addresses. Commenting is no longer used on GuerillaStockTrading.com but may be in the future.
- The website firewall processes IP-addresses and user locations. The firewall is used to block malicious IP-addresses, bots, scrapers, and more. In addition, countries that sponsor hacking attempts against U.S. websites such as China, Russia, and North Korea are also blocked. Smaller countries that lack resources that are used for proxy attacks are also blocked. Lance Jepsen conducts firewall audits and updates the blocked countries list and blocked IP-addresses list weekly if necessary. Lance Jepsen has worked in IT cybersecurity and has taken actions to lock down and secure The Business. The Department of Homeland Security bulletins are regularly monitored and preemptive actions are taken as needed. The Business is for U.S. based traders and as such most other countries are blocked. Proxy access is prohibited and proxy IP ranges are blocked when discovered.
- A cloud-based backup solution is used which stores encrypted backups in their secure data centers.
- Google Analytics is used to determine which pages are receiving the most traffic. No identifiable personal information is collected with Google Analytics. Data is kept in Google Analytics for 14 months and then is deleted. Data collection Remarketing is off, Demographics data collection is off. Anonymize IPs while tracking is turned on.
- Number of log ins and last log in date is kept with customer accounts.
c. Services outside the EU
Google, Paypal, and Stripe are all working to become complaint with GDPR regulations.
Personal data is only stored for paying subscribers. When a subscription is cancelled or deactivated, all customer data which consists of name, email address, and phone number (if customer opted in to the mobile phone text alert service) is deleted from the database. Audits are done every month. All requests to permanently delete accounts are honored and promptly carried out within 24 hours.
No marketing automation or A/B-testing is used.
2. Why personal data is stored
Subscriber data is stored on The Business website database only.
- Data is stored by consent, for:
Paid subscription on The Business website.
- To allow paying subscribers to login and access non-public portions of the website.
- Consent is freely given (users are not to be misled or forced)
- Consent is explicit (that means no tick box checked by default!)
- Consent is given per component (e.g. subscription for website access, mobile phone instant text alerts)
- Subscribers can cancel and withdraw their permission at any time.
- Tracking all website visitors IP-addresses in the firewall is justifiable
to protect against hacking attempts from locations around the world. Also to protect against bots that scrape and illegally take content from The Business and re-post that content on other sites or mobile apps.
- Personal requests
Individuals may request that their customer data (Name, Email Address, and Mobile Phone Number) be deleted from the website by sending an email to firstname.lastname@example.org. Individuals can also cancel their subscription service through their Account area dashboard or send an email to email@example.com.
Customer data is kept confidential and is protected behind two firewalls of both the website firewall and the JetPack firewall. Jetpack also does malware and antivirus scans of the website. In addition, Symantec antivirus and firewall is used to protect the computer of Lance Jepsen who accesses the website dashboard backend. Plugin developers are not given access to the dashboard backend and plugins are removed that have errors and require a developer to access the backend. Plugins are also removed that are outdated and not kept up to date by the developer. Plugins are scanned for malware. The website CMS is updated within 24 hours after new security updates become available.
- Data breaches
In case of data breaches, the FBI will be notified along with the EU Personal Data Protection Authority within 72 hours.