FreeToastHost Privacy and Cookie Policy

Written by FreeToastHost on . Posted in Documentation

Effective May 25, 2018

 

Your Privacy Matters

FreeToastHost 2 is a free website provider, content management system, and email list server for the exclusive use of Toastmasters clubs and districts in good standing. Use of this system is strictly for purposes of Toastmasters related activities and business. We take privacy very seriously and it is our intention to be transparent about the data we collect about you, how it is used and with whom it is shared.

This Privacy and Cookie Policy applies when you use our website system or email list server (described below). We offer our users choices about the data we collect, use and share as described here.

Table of Contents:

Introduction

We are a free website provider, content management system, and email list server for the exclusive use of Toastmasters clubs and districts in good standing. Toastmasters clubs and districts use our system and services to greatly simplify the effort needed to produce a good website while additionally making use of custom FreeToastHost provided functionality for club operations and communications. Our Privacy and Cookie Policy applies to any Member, District Leader or Visitor making use of our websites, our email system or other FreeToastHost provided services.

Our registered users ("Members" or "District Leaders") share their contact information to communicate with other Members and District Leaders, engage with other Members or District Leaders in their club or District, sign up for meeting roles online, post and view relevant website content, and learn new communications and leadership skills in the Toastmasters educational programs. Content and data on some of our Services is viewable to non-members ("Visitors").

We use the term "Designated Countries" to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

Services

This Privacy and Cookie Policy applies to your use of our Services.

This Privacy Policy applies to www.toastmastersclubs.org, all sub-domains of www.toastmastersclubs.org, the FreeToastHost support website (support.toastmastersclubs.org), FreeToastHost websites using a user-registered custom domain, and associated communications and services ("Services"), but excluding services that state that they are offered under a different privacy policy.

Data Controllers and Contracting Parties

Your personal data is stored on and controlled by our FreeToastHost server located at IP address 50.19.253.65

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy and Cookie Policy and updates.

Change

Changes to the Privacy Policy apply to your use of our Services after the "effective date."

FreeToastHost ("we" or "us") can modify this Privacy and Cookie Policy, and if we make material changes to it, we will provide notice via email, or by other means, to provide you the opportunity to review the changes. If you object to any changes, you may request deletion of your FreeToastHost website.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy and Cookie Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy and Cookie Policy.

 

1. Data We Collect

1.1 Data You Provide To Us

You provide data to create a FreeToastHost website (website administrator's contact information) and Members / District Leaders provide data as part of being registered with the club or district website, respectively.

Registration

To create a FreeToastHost website you need to provide data including your name, email address, and the club or district number that you are requesting a website for as the new website's administrator. Upon approval by recognized club or district "authorities" (e.g., email address on toastmasters.org), the administrator will receive an email via the provided email address containing link to set their administrator password. The website administrator is a "superuser" role recognized by the FreeToastHost system for administration of club / district websites. Only one registered website administrator is recognized by the system, but the website administrator has the ability to delegate certain administrator functions to club / district officers.

The website administrator is a distinct role recognized by the system and does not have a profile, per se, as the role is associated with the regular club or district website maintenance and administration. The website administrator does not have to be a registered Member / District Leader in the website.

To become a registered users of a FreeToastHost website as a Club Member or District Leader, you generally need to provide your name and email address, at a minimum to the club / district website administrator or their delegate to be entered into the website. You can optionally provide a phone number that is only visible to other registered users of the website. When you are registered, you can gain access to other club members / district leaders contact information by requesting a new password link be emailed to you when you log in.

You can still use the website if you do not provide an email address, but you will experience fewer benefits from using the website if you do that. You would not be able to receive emails from the club / district distribution lists, you would not be able to receive emailed meeting agendas, and you would not be able to receive notifications from the website intended to be of benefit to you. The system does contain a number of settings available via your Member Profile to enable you to control which notifications you would like to receive and which you do not want to receive.

Once you have obtained a Club Member / District Leader password for your club / district website, you can access and edit your member profile to optionally add additional details about yourself and set your website usage preferences.

Profile

You have choices about the information on your profile, such as a secondary email address, your phone number, your Toastmasters member number, your email preferences, your social media links, a short biographical summary, and your photo. You don't have to provide additional information on your profile; however, profile information helps you to get more from your website, including facilitating familiarity and communication with other club members / district leaders, enabling you to easily sign up for Toastmasters meeting roles, and helping your club or district attract other members and district leaders. It's your choice whether to allow your name, biographical information, and photo to be listed on the club/district's Meet Our Members web page—by default, that is disabled. Please do not post or add sensitive personal data to your profile.

By default, when a new member or district leader is added to a FreeToastHost website, the "Allow Administrator Edits to my Profile" setting is enabled to allow the member to quickly be added to the system (with the administrator's assistance). However, once the member is registered in the system, gets their password, and obtains access to their member profile, this setting can be disabled to prevent further changes to the profile by the website administrator or their delegate. If the member chooses to leave this setting enabled, they will be notified whenever someone other than themselves has edited their profile.

1.2 Data From Others

Website Content

You and others may post content that includes information about you (as part of web pages, meeting agendas, meeting notices, forum posts, comments, member emails, and videos) using our website system. FreeToastHost does not make use of this information for any reason other than to compose web pages for your club / district website.

Contact Information

We may receive personal data (including contact information) about you when you complete the Contact Us form or send messages using our email services.

Toastmasters International

We may receive publicly available contact information from Toastmasters International (e.g., information published on Find a Club pages).

1.3 Service Use

We log your visits, use of our websites, use of our email services, and file uploads to our websites. If your club / district has elected to use Google Analytics, then the pages you visit on the website will also be logged via that service.

We use log-ins, cookies, device information and internet protocol ("IP") addresses to identify you and log your use.

1.4 Cookies and Other Similar Technologies

We collect data through cookies and similar technologies.

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., HTML5 local storage and device identifiers) to recognize you and/or your device(s) on, off and across different websites and devices. We also allow some others to use cookies as described in our Cookie Policy (e.g. Google Analytics). You can control cookies through your browser settings and other tools.

1.5 Your Device and Location

We may receive data from your devices and networks, including location data.

When you visit our websites, we receive the URL of the site you came from. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier.

1.6 Messages

If you communicate through our email services, those communications are logged for troubleshooting purposes. (All emails through the system are logged.)

We collect information about you when you send, receive, or engage with messages in connection with our websites and email services.

1.7 Other

We are often improving the FreeToastHost website system, which means we get new data and create new ways to use data.

Our system is dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy and Cookie Policy.

 

2. How We Use Your Data

We use your data to provide, support, personalize and develop the FreeToastHost Website System and email services.

How we use your personal data will depend on which website features you use, how you use those website features and the choices you make in your website settings member profiles. We use the data that we have about you to provide custom websites and personalize user experiences, including email, including with the help of automated systems and inferences we make, so that they can be more relevant and useful to you and others.

2.1 Services

Our services provide free websites, custom Toastmasters-focused functionality (e.g., meeting agendas), and email communications for Toastmasters in good standing.

We use your data to authorize access to our Services.

Websites for Toastmasters Clubs and Districts

Using our website template, we provide websites filled in with your custom content for a appealing website that represents your club or district.

Custom Functionality

FreeToastHost provides some custom functionality such as online meeting agendas that are intended to simplify Toastmasters club operations. You are not obligated to used this custom functionality—it can be disabled.

Email Communications

We provide an email list server that supports email distribution lists and officer email addresses. You can also create custom email addresses and distribution lists.

2.2 Communications

We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages (e.g, meeting notifications).

We will contact you through email or messages viewable when you log in to your website. We will send you messages about the availability of our services, security, or other service-related issues. We may also send messages about system updates, reminders, documentation updates, and useful forum posts from our support forums. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

2.3 Developing Services and Research

We continue to develop our system and may collect usage data or conduct surveys to determine how to best use our limited resources for further development.

Service Development

We use information, including public feedback, from our support forums, database queries, and user surveys to inform our decisions about how to further develop the FreeToastHost website system in order to provide you and others with a better, more intuitive and personalized experience and facilitate good communications.

Surveys

Polls and surveys may be conducted by us and others through our support forums. You are not obligated to respond to polls or surveys, and you have choices about the information you provide.

2.4 Customer Support

We use data to help you and fix problems. We may collect debugging information in testing logs when troubleshooting a problem that could include personal information. This debugging information is flushed from the system regularly.

We use the data (which can include your communications) to investigate, respond to and resolve complaints and FreeToastHost system issues (e.g., bugs).

2.5 Aggregate Insights

We use data to generate aggregate insights. This is typically done via database queries to determine what settings have been changed from the default settings.

Clubs and districts may collect additional information via services such as Google Analytics which tracks what web pages are being accessed.

2.6 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) if we think it's necessary for security purposes or to investigate possible fraud or other violations of our Terms of Use Agreement or this Privacy and Cookie Policy and/or attempts to harm or mislead our Members, District Leaders or Visitors.

 

3. How We Share Information

3.1 Our Services

If you elect to share your member information on the Meet Our Members page, your name, officer role (if an officer), social media links, and your bio will be seen by others.

Profile

Your profile is fully visible to the club/district Website Administrator and any club/district officers that the Website Administrator has granted access to. If the setting allowing them to edit your profile is enabled, they may also edit your profile on your behalf. You will receive a message whenever your profile is edited by someone other than yourself.

3.2 Communication Archival

While FreeToastHost does log email header information for troubleshooting purposes, we only store complete emails that are designated as Spam by our Spam Detection service (SpamAssassin) to enable us to improve our spam detection. FreeToastHost does not provide email accounts, and no complete emails are archived or stored other than for the Spam detection case.

Some clubs and districts may elect to provide an email address for the FreeToastHost email services to copy emails to that are sent through the FreeToastHost email system. The intent of this is to provide a mechanism for clubs and districts to archive their email communications. It should be noted that the system just copies all emails it processes to the provided email address (no filtering). It is possible that some of your personal information could be in those emails in that email account—if this is of concern to you, you should ask the Website Administrator if the archival account feature is in use.

3.3 Others' Services

FreeToastHost does not provide any kind of links to your personal information to any outside services..

3.4 Related Services

We may access your personal information as part of our overall troubleshooting and/or maintenance of the FreeToastHost system as a whole. This means that our system developer(s), support staff (FreeToastHost "Ambassadors"), and technical advisors may encounter your personal information when attempting to assist a club or district to resolve problems and our developer(s) may encounter it as part of making system improvements.

3.5 Service Providers

At this time, FreeToastHost is not dependent on any external service providers that would have access to your personal information.

3.6 Legal Disclosures

We may need to share your data when we believe it's required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of FreeToastHost, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.7 Change in Control or Sale

We may share your personal data as part of a change in control of FreeToastHost or in preparation for that. In that event, this agreement would still be in force, unless you agree otherwise.

 

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected and used.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your member profile and controlling the visibility of your information on the public Meet Our Members page to communication and email controls.

For personal data that we have about you:

  • Delete Data: You can request that your personal data be deleted (e.g., if you are not longer a Member).
  • Change, Correct, or Limit Data: You can edit some of your personal data through your Profile. You can also ask us to change, update or fix your data in certain cases, particularly if it's inaccurate or corrupted. You can also limit the amount of information about you used by FreeToastHost by deleting it from your Profile.
  • Right to Access and/or Take Your Data: You can request a copy of your personal data and can ask for a copy of personal data you provided in machine readable form. Your website administrator can provide your information in a CSV file format, which is very portable and machine readable.

For more information you may contact us via our support forums.

Residents in the Designated Countries may have additional rights under their laws.

4.3 Account Closure

We keep some of your data even after you stop being a member or request deletion of your website. This retention is just to allow for simple reactivation (un-deletion) in the event of mistakes. In general, deleted information for members is slated for purging after 30 days, and deleted websites are slated for purging after 90 days. Deleted information that is retained in this way is kept in a hidden state and is not accessible to anyone except the website administrator, their delegates, or system administrators in the event that one of them chooses to un-delete the information.

We may also retain your personal data even after you have closed your account if reasonably necessary to comply with legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use Agreement, or fulfill your request to "unsubscribe" from further messages from us.

 

5. Other Important Information

5.1. Security

We monitor for and try to prevent security breaches. Please enable and use the security features available through the website Administration Console.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2. Cross-Border Data Transfers

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. "Processing data" can include data processed by scripts both on our server and browser scripts run via your computer or device. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

5.3 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

At any time, you can withdraw consent you have provide by requesting removal from the system.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent) and "legitimate interests".

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

5.4. Direct Marketing

We do not share personal data with third parties for their direct marketing purposes.

5.5. Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Policy, please contact our support team via our online support forums at https://support.toastmastersclubs.org.