Privacy Policy

Welcome to www.frombroadwaytothenarrowway.com. Data protection and data security when using our website are very important to us. We would therefore like to inform you which of your Personal Data we collect when you visit our website and for what purposes it is used.

Who is responsible?

The person responsible in the sense of New York’s Online Privacy, and Consumer Protection Regime and the EU’s General Data Protection Regulation (“GDPR”) is From Broadway To The Narrow Way, Jordan Scott Gilbert, New York, USA (“we”, “us”, or “our”). Please direct any questions you may have to us using our Contact Form.

Principles of data processing

a)  Personal data

Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behavior.

b)  Processing 

Processing means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data. The processing of Personal Data always requires a legal basis. 

c)  Legal basis

We have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfillment of a contract / pre-contractual measures, iii) the data is necessary for the fulfillment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden. 

d)  Retention

We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular applicable commercial and tax laws). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted. 

Data we collect

a)  Provision and use of the website

When you call up and use our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.

b)  Hosting 

The hosting service used by us for the purpose of operating our website is GoDaddy.com. In doing so, GoDaddy processes inventory data, contact data, content data, usage data, meta data and communication data of interested parties and visitors of our website, on the basis of our legitimate interests.

c)  Content Management System

We use the Content Management System (CMS) of WordPress, a service provided by Automattic Inc (60 29th Street Suite 343 San Francisco, CA 94107 USA) to publish and maintain the created and edited Content and texts on our website. This means that all content and texts submitted to us by users for publication is transferred to WordPress. In addition to texts, this also includes, for example your data in our forms. The legal basis for this processing is our legitimate interest.

d)  Fonts

We have integrated Google Fonts by Google LLC, and Font Awesome of Fonticons Inc. To enable the display of fonts, a connection to Font Awesome’s and Google’s server is established when our website is accessed. This enables Google and Fonticons to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.

e)  Google reCAPTCHA

We also use Google's reCAPTCHA from Google to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as you enter our website. The legal basis for using reCAPTCHA is our legitimate interest.

f)  Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

g)  Economic analyses and market research

For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use Google Analytics from Google. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy.

h)  Cookie consent 

Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.

i)  Contacting us

We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.

j)  Contractual Services

We process the Personal Data involved when you enter into a contract with us in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

k)  When participating in our Coachings

When you are using our coaching services you can provide a variety of data. Doing so we process various data within the framework of the provision of our services and for the initiation and processing of the existing contractual relationship between you and us. Thus, if you have commissioned us to provide a service, such as coaching, we process your Personal Data and all information that is necessary in the context of fulfilling the services, exclusively for the purpose of processing and handling the contractual relationship.

Further and through the performance of our services, we may collect Special Category data. Special category data is personal data that needs more protection because it is sensitive. This may include personal data revealing racial or ethnic origin, religious or philosophical beliefs, genetic data, biometric data, or data concerning health. If the processing of Special Category data during the course of the provision of services becomes necessary, we need to obtain the data subjects consent in Article 9 Para. 2 lit. c), h) GDPR.

In this context, consent means any freely given indication of the data subject's wishes for the specific case in an informed and unambiguous manner, in the form of a declaration or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her. 

Accordingly, and when you use our services, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations and the consent of the relevant service user.

l)  Payment Data

If you make a purchase your payment will be processed via our payment service providers GoDaddy and PayPal. Payment data will solely be processed through GoDaddy or PayPal and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

m)  Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest. 

n)  Promotional use of your data

We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.

o)  Testimonials 

Within the testimonial section, we may display certain Personal Data, share certain details, knowledge and insights. When you approve and submit your testimonial to us your consent is obtained, and you have choices about the information in your testimonial. The storage and publication of testimonials is based on your consent. 

How we may share your Personal Data

We may share your Personal Data with our Business Partners for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customizing our services to better meet your needs. We share your Personal Data only with Business Partners who agree to protect and use your Personal Data solely for the purposes specified by us. 

We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests. Except as described above of which you will be informed in advance, we will not disclose your Personal Data.

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

Data Security

We undertake to protect your privacy and to treat your Personal Data confidentiality. In order to prevent manipulation or loss or misuse of your data stored with us, we take extensive technical and organizational security precautions which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS).


However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

Marketing 

Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us. 

You can revoke your consent to receive our newsletter at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data. 

Social Media

General

We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

Market research and advertising

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.

When you visit our profiles and interact with us and others

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

Advertising

We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.

We also analyze this data to evaluate the relevance of the advertisements and to optimize the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website. The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.

What we do not do

●  We do not request Personal Data from minors and children;

●  We do not use Automated decision-making including profiling; and

●  We do not sell your Personal Data.

Privacy rights 

You can exercise the following rights:

●  Right to information

●  Right to rectification

●  Right to deletion

●  Right to data portability

●  Right of objection

●  Right to withdraw consent

●  Right to complain to a supervisory authority

●  Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact me.

COPPA (Children Online Privacy Protection Act)

We do not specifically market to children under the age of 13 years old.

CAN SPAM Act

In accordance with CAN SPAM, we agree to unsubscribe you from receiving future emails and ALL other correspondence, immediately if you ask us to do so.

Controls For Do-Not-Track Features

At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. If a standard for online tracking has to be adopted, we will do so and will inform you about that practice in a revised version of this policy.

Telephone Consumer Protection Act (TCPA)

If we are sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’.

Updating your information and withdrawing your consent 

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or want to withdraw any consents you have given us, please contact us. 

Access Request 

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Changes

We are constantly developing and improving our website - and as a result, some of the information in this Privacy Policy is likely to change. We therefore recommend that you read this Privacy Policy again from time to time so that you are informed about the current status. This Privacy Policy was last updated on Friday, February 9th, 2024.

Questions

If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.