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Privacy Policy Tim Berners-Lee, the inventor of the web, said
On my website, this privacy policy is linked at the bottom of (almost) every page. I created this privacy policy in order to demonstrate my firm commitment to privacy. This page discloses my information gathering and dissemination practices for my website: James S. Huggins' Refrigerator Door. As you can see, it was not written by lawyers! Other Privacy Pages On My Site CIPEA Tone On Wednesday, 26.Jul.2000, Senators Spence Abraham, John McCain and John Kerry introduced the Consumer Internet Privacy Enhancement Act (CIPEA). This proposed legislation never made it into the law. But I used the law as a model to construct a privacy statement which would comply. I did it as an exercise in learning more about privacy principles. I have created a CIPEA privacy disclosure page (which I call CIPEA Tone) to clarify the the notices proposed by CIPEA (Consumer Internet Privacy Enhancement Act). All of the disclosures on the CIPEA Tone page are duplicates of disclosures on my privacy page, but they have been "organized" according to the structure of CIPEA. This page also provides background and impact information regarding CIPEA and links to other articles and resources for CIPEA. COPPA Cabana I have created a COPPA Privacy Disclosure page (which I call COPPA Cabana) to provide the notices required by COPPA (Children's Online Privacy Protection Act) related to information practices of this site regarding personal information and privacy of children. This page also provides background and impact information regarding COPPA and links to other articles and resources for COPPA. OECD Privacy Statement A long, long time ago, on 23.Sep.1980, the Organization for Economic Co-operation and Development, (OECD), issued Guidelines on the Protection of Privacy and Transborder Flows of Personal Data. (Did you notice that date? 1980!! Privacy issues are not new.) Recently OECD created the OECD Privacy Statement Generator to help organizations create privacy statements to post on websites. I have created an OECD Privacy Disclosure page (which I call OECD Privacy-D) to stipulate how this site complies with the seven privacy principles. All of the disclosures on the OECD Privacy-D page are duplicates of disclosures on my privacy page, but they have been "organized" according to the structure of the OECD Privacy Principles. This page also provides background and impact information regarding the OECD Privacy Guidelines links to other resources for the OECD Privacy Guidelines. Scenic Overlook I don't really care who you are. I don't really care if you are married, or where you live, or how many goldfish you have. I do care about your privacy. I only collect personal information in four ways:
Privacy Principles The principles of web/internet personal privacy are based on:
History of the Privacy Principles In 1972, Elliot L. Richardson, as Secretary of HEW (the U.S. Department of Health Education and Welfare), created an Advisory Committee on Automated Personal Data Systems. Their charter was to explore the impact of computerized record keeping on individuals. One year later (1973) the committee published its report. This report, Records, Computers, and the Rights of Citizens , proposed a Code of Fair Information Practice:
These principles began a basis for subsequent codes and laws related to information collection. The principles became part of the framework for the Privacy Act of 1974. They were elaborated on when the Privacy Protection Study Commission (PPSC) published its report Personal Privacy in an Information Age. In 1980, The Organization for Economic Cooperation and Development further refined them in Guidelines on the Protection of Privacy and Transborder Flows of Personal Data. They also form a basis of the EU Privacy Directive. And, you can see them discussed in Part III of the 1998 Federal Trade Commission report: Privacy Online. They continue today to be advocated and incorporated into enforcement initiatives, laws and legislative proposals. Notice People are entitled to notice of the collection, use and disclosure of personal information. The notice should include:
The notice should also address the other principles of choice, access, security and enforcement. Choice People should have choices about how their information is used or disclosed to third parties. Choice may be "opt in" in which people affirmatively consent to the use or disclosure. Or the choice may be "opt out" in which the consent is presumed unless people object. "Opt in" provides strong privacy protection because it establishes a default rule against disclosure and use. It is generally agreed that the choice is about use and disclosure beyond the original purpose for which the information was provided. Use and disclosure to complete a purchase transaction is, of course, required. However, such use and disclosure should be the minimum required to complete the transaction. Access People should have access to information stored about them, together with the opportunity to correct the information or to have it deleted. Security Operators should protect the security of personal data and ensure its integrity and accuracy. Enforcement Of course, none of these make any difference if if the principles are not enforceable. How to enforce is at the heart of a gigantic debate including proposals for self-regulation and counter-proposals for additional federal legislation. Privacy Principles On This Site The five principles are important to this site. I take them seriously. Notice I provide complete (some say too complete) disclosure on this page. In addition, on my COPPA Cabana page I disclose information specific to children and privacy. And on my CIPEA Tone page, I disclose this same information in a format more suitable to understanding that proposed law. Choice I give people choices. No one needs to disclose personal information if they don't want to. Except for the obvious (like not receiving an email from me if you don't give me your email address) there are no consequences of nondisclosure. You do not need to disclose information to surf my site. All disclosure is "opt in". Access I provide people access to information stored about them, together with the opportunity to correct the information or to have it deleted. Security I protect the security of personal data and ensure its integrity and accuracy. Enforcement I consider this agreement to be enforceable between us. I even provide alternative organizations to notify if you think I'm not holding up my end of the bargain. Who Operates This Site? I do, James S. Huggins. Just me. No one else. At the bottom of this page I have listed my address and phone numbers. Minimal Information For activities related to this site, I only use the absolute minimum information required. For example, when you join one of my email/ezine lists (e.g., Snippets and TestZine), list I keep your email address (because it really wouldn't make much sense to have an email list if I didn't keep your email address). And I keep information necessary to provide an audit trail in order to comply with the CAN-SPAM Act of 2003. Also, if you write me, I'll use your email address to write you back. (duh!) As another example, when you click around my site, my server log files record how you clicked around. But the information doesn't tell me who you are, only that someone went from one page to another. And I only use that information to analyze traffic and don't keep it or use it beyond that. Sharing Information I don't share information. I keep any information you disclose absolutely private. This does not apply of course to the Guestbook. Information disclosed there is shared with the whole world. But that is the whole point of a Guestbook, isn't it. Unsolicited Email Spammers are the scum of the earth. I will never give away, sell or disclose your email address. I never email you just because you visited my site because I won't have your email address. I only email you because you explicitly ask me to (e.g., to respond to a request or because you explicitly asked to join one of my email/ezine lists (e.g., Snippets and TestZine), or to thank you for signing my guestbook.) Taping Our Phone Conversations I am your friend. I am a real friend, not a Linda Tripp friend. I promise not to tape our phone conversations without telling you. Policy Changes I'm committed to privacy. I won't arbitrarily change these policies. I can't even envision changing these policies at all. But if I ever do change these policies, the changes won't be "retroactive". The changes will only apply to new information. Your info is safe. Period. End of story. Information Collected I collect information in four ways:
Information Collected By the Webserver If you visit this site, the webserver will automatically collect:
Information Collected for My Email/Ezine Lists When you join any of my email/ezine lists (e.g., Snippets and TestZine), I keep your email address (because it really wouldn't make much sense to have an email/ezine list if I didn't keep your email address). And I keep information necessary to provide an audit trail in order to comply with the CAN-SPAM Act of 2003. Here is a list of Subscription Information that I keep for all email/ezine lists I host on my site using my Gammadyne Mailer system: Personal and Status Information
Current Issue Information
Subscription Process Information
Unsubscription Process Information
Pending Confirmation Information
Miscellaneous Information
EzinePrivacy.org I follow the Core Principles of Ezine Privacy from EzinePrivacy.org. I defend the privacy of ezine subscribers and never track personal information, like when you open my ezine and whether you forwarded it to a friend. Information Collected Through My Guestbook If you sign my Guestbook, the Guestbook will show whatever information you leave. If you leave me your email address, it will show your email address. If you leave your name, it will show that. If you leave the URL of your website, it will show that. If you leave your name, your dog's name and your birthday, it will show that. In addition, it will show the TCP/IP address you use to post as well as information your browser supplies about the browser. Information Collected Through Email to Me If you send me an email, I will have your email address as well as anything else you tell me. Cookies I don't use cookies. Period. Children's Data I don't knowingly collect data from children. I use simple tools to discourage disclosure by children. And, if I discover personal data from children, I delete it. For more information, see my COPPA Cabana page. Information Not Collected I don't collect anything else. I don't have any "real" registration forms for you to fill out. (I do have parody and joke forms like my McDonnell Douglas Military Aircraft Warranty Card. But the information you fill out there, doesn't really go anywhere and isn't kept.) Use of Collected Information Use of Webserver Information When you click around my site, my server log files record how you clicked around. But the information doesn't tell me who you are, only that someone went from one page to another. And I only use that information to analyze traffic and don't keep it or use it beyond that. Also, you can block that information using a tool like AdSubtract. If you don't send that information, there are no consequences. I do not require disclosure of that information to browse my site. Use of Email/Ezine List Information My email/ezine lists are is compiled through requests to me. I only use this information to email email/ezine lists (e.g., Snippets and TestZine). If you don't give me your email address, I won't be able to email you. But there are no other consequences. I do not require disclosure of that information to browse my site. Use of Site Guestbook Information If you leave me your email address, I will send you a thank you email for signing my Guestbook. If you leave me your website URL, I might visit your site. If you tell me how to win the lottery, I might try your technique. But, I won't put you on an email list or sell my Guestbook information. (Of course, anyone who wants my Guestbook information can get it directly off the Guestbook without asking!) If you don't sign my Guestbook, the whole world won't see your personal information. But there are no other consequences. I do not require disclosure of that information to browse my site. Use of Email Information If you write me an email, I'll use the information in that email to write you back. Unless you ask me to, I won't put you on an email list. And I won't chare that information with other people. If you don't write me an email, nothing bad happens. There are no other consequences. I do not require disclosure of that information to browse my site. Other Links This site contains links to other sites. Unfortunately, I can't do much about the privacy practices of such websites. So you all be careful out there. When you link through my site to other sites (e.g., Amazon.com) your browser may tell the other site that you came from one of my pages. This is called referrer information. Now, I don't actually send that information; your browser does. But you should know that it is possible for you to block this information. To find out how, see my information on the tool AdSubtract. This site doesn't send any personal information to other sites partners. SecurityThis site has security measures in place to protect the loss, misuse and alteration of the information under our control. For example, my Internet Presence Provider provides userid and password access control to all web captured information (TCP/IP address information). Also, I am the only one with access to my email/ezine lists (e.g., Snippets and TestZine). Choice/Opt-OutOpt-Out of Email/Ezine Lists You may opt out of my email/ezine lists (e.g., Snippets and TestZine) by following the directions included in every mailing. Each ezine supports an email based unsubscribe and a web based unsubscribe. You can also email me. Opt-Out of GuestbookThere is no "automatic" way to remove your information from my Guestbook. However, you may email me and I will gladly remove your entry. Correct/UpdateCorrection of Snippets You correct your information for my email/ezine lists (e.g., Snippets and TestZine) by following the directions included in every mailing. You can also email me. Correction of GuestbookThere is no "automatic" way to correct your information on my Guestbook. However, you may email me and I will gladly remove your entry. Contacting the WebsiteIf you have any questions about this privacy statement, the practices of this site, or your dealings with this website, you can email my special privacy address. If You Think I Am Not Following My PolicyIf you feel that I am not following these stated information policies, you may contact
Privacy CertificationsThis site was reviewed by enonymous.com and rated with the 4-Star and Best Privacy designations. This organization has since disbanded. James S. Huggins Links On My Site
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This page created: before Wed, 10.May.2000
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