3 - Privacy Policy - Author Bella Barwin

Privacy Policy

Effective date: September 14, 2025

1. INTRODUCTION AND DEFINITIONS

Hi! I’m Bella Barwin (“I”, “me”, or “my”), an author of dark science fiction romance and dark vampire romance. I’m committed to protecting your privacy. I also promise not to spam you. No one wants a ton of email clogging up their inbox. I understand the trust you place in me when you provide me with your name, email address, and any information capable of identifying you as a specific individual, sometimes known as personally identifiable data. (collectively, “Personal Data”). I won’t abuse that trust.

This is the Privacy Policy for my websites, https://bellabarwin.com/, https://www.authorbellabarwin.com, or any other service or website I offer or authorize to which this Privacy Policy is linked and listed HERE [URL] (collectively, “Websites”) Some jurisdictions call this a Privacy Notice, but this Privacy Policy serves the same purpose.

This Privacy Policy provides you (the “User”) with details of how I collect, store, use, access, and/or share (collectively, “process”) your Personal Data when you visit, access, use or engage my Websites and the content, products, and services available through my Websites. It also details how I process your Personal Data when you use my other services separate from my Websites (“Services” ). Websites, Services, or both, process your Personal Data, including but not limited to when:

You visit, access, use, or engage with my Websites;
You engage with me in other related ways, such as:
- registering to become a VIP Reader and consenting to receive my newsletter,
- downloading promotional eBooks,
- registering to become an Early Reader,
- downloading an Advance Review Copy of an eBook
- agreeing to be a Beta reader,
- downloading a Beta copy of an eBook, or
- contacting me via email or through my contact page;
You receive Author Bella Barwin’s newsletter, any other content I distribute, or both;
You engage with me through my newsletter, other content I distribute, social media, or other communication networks;
You click on an advertisement or other link for my promotions, services, offers, or products;
You enter a giveaway I sponsor or co-sponsor;
You provide me with your Personal Data through “authorized third-party service providers” (see definition in section 6 below) who perform or support the above listed functions;
You engage with me offline (for example, you fill out a sign-up sheet at an in-person event or send me a letter via US mail).

By using my Websites and Services, you are accepting and consenting to the practices described in this Privacy Policy and related Terms of Use. Depending upon where you are located geographically, your jurisdiction may grant you certain rights regarding your Personal Data.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING MY WEBSITES, SERVICES OR BOTH, YOU ACKNOWLEDGE THAT YOU HAVE READ, YOU UNDERSTAND, AND YOU AGREE TO BE BOUND TO ALL THE TERMS OF THIS PRIVACY POLICY AND THE TERMS OF USE FOR MY WEBSITES AND SERVICES.

IF YOU DO NOT AGREE TO THESE TERMS, PLEASE EXIT THIS PAGE AND DO NOT USE MY WEBSITES OR SERVICES.

Questions or concerns? If you have any questions or concerns about my Privacy Policy or otherwise wish to exercise your privacy rights, please contact me. My contact information is in the last section of this policy.

2. PROCESSING LOCATIONS OF THE PERSONAL DATA I COLLECT

My Websites are hosted in the United States of America (“United States” or “US”), as are my other authorized third-party service providers. However, your Personal Data may be processed in other countries by me as I travel and work remotely. It may also be processed in other countries by authorized third-party service providers I retain in the future.

YOU AGREE THAT BY USING MY WEBSITES, SERVICES, OR BOTH, YOU ARE PROVIDING YOUR EXPLICIT AND EXPRESS CONSENT THAT YOUR PERSONAL DATA MAY BE TRANSFERRED OUTSIDE YOUR COUNTRY, YOUR UNION OF COUNTRIES, OR YOUR UNIFIED MARKETS, INCLUDING OUTSIDE THE EUROPEAN ECONOMIC AREA (“EEA”), AND YOU HAVE READ THE POSSIBLE RISKS IN SECTION 14, 15, AND 16 BELOW.

MY WEBSITES AND SERVICES ARE NOT INTENDED FOR DISTRIBUTION TO OR USE BY ANY PERSON OR ENTITY IN ANY JURISDICTION OR COUNTRY WHERE SUCH DISTRIBUTION OR USE WOULD BE CONTRARY TO LAW OR REGULATION OR WHICH WOULD SUBJECT ME TO ANY REGISTRATION REQUIREMENT WITHIN SUCH JURISDICTION OR COUNTRY.

ACCORDINGLY, THOSE PERSONS WHO CHOOSE TO ACCESS, REGISTER FOR, OR USE MY WEBSITES OR SERVICES FROM SUCH LOCATIONS DO SO ON THEIR OWN INITIATIVE AND ARE SOLELY RESPONSIBLE FOR COMPLIANCE WITH LOCAL LAWS, IF AND TO THE EXTENT YOUR LOCAL LAWS ARE APPLICABLE.

3. YOU MUST BE AT LEAST 18 YEARS OLD TO USE MY WEBSITES OR SERVICES

By using my Websites, Services, or both, or by providing me with your Personal Data, you warrant to me that you are 18 years of age or older and you also warrant to me that you are not a minor where you reside. My Websites and Services are directed to adults.

You must be at least 18 years of age to use my Websites, Services, or both, including but not limited to registering as a VIP Reader and subscribing to my newsletter, requesting to be an Early Reviewer, or agreeing to be a Beta reader. Persons under the age of 18 are not permitted to access, register for, or use any Website or Service I provide.

4. CHANGES TO THIS PRIVACY POLICY

I reserve the right to modify or amend the terms of my Privacy Policy from time to time without advance notice. If I make a material change in the way I use your Personal Data, I will provide prominent notice of the change on this Privacy Policy page and update the policy date at the bottom of this page. Your continued use of my Websites, Services, or both, or continued receipt of my newsletter or other email communications following the posting of changes to these terms will mean you accept those changes unless I am legally required to obtain your affirmative consent.

Some Users have certain legal rights. To the extent you cannot waive your rights and have registered with me in violation of my Terms of Use, I reserve the right to continue to process your Personal Data pursuant to your consent and any other legal basis set forth in this Privacy Policy. I will use reasonable efforts to identify those Users covered by laws that require consent when I change or materially modify my Privacy Policy, and for those Users, obtain such consent prior to using your Personal Data based on consent.

5. DATA CONTROLLER

I am the Data Controller and I am responsible for processing your Personal Data pursuant to my Privacy Policy. When you provide Personal Data to me or one of my authorized third-party service providers, you consent to the transfer of the data to me and processing by me.

6. HOW I PROCESS YOUR PERSONAL DATA USING AUTHORIZED THIRD-PARTY SERVICE PROVIDERS

a. Authorized third-party service providers

An “authorized third-party service provider” is an independent company or individual contracted by me to process data on my behalf pursuant to my instructions and are sometimes referred to as “data processors.” They provide specialized services or functions that are not my core business of writing. These authorized third-party service providers perform the following functions, including but not limited to:

managing the distribution of eBooks—advance review copies, beta read copies, or eBook giveaway prizes;
managing my email list, including distribution of my newsletter;
fulfilling orders, delivering packages, sending postal or email;
administering contests, giveaways, or sweepstakes;
providing cloud storage or cloud software;
removing repetitive information on customer lists;
analyzing data;
providing marketing assistance;
providing search results and links;
providing and troubleshooting IT and system administration services, including website hosting, programming platforms, other software, and related apps;
operating my Websites;
providing customer service;
providing survey services;
assisting in conducting my business and serving you.

These external entities handle tasks that I may lack the internal expertise or resources to manage, allowing me to save time and money, maintain focus on writing and publishing, and efficiently access specialized skills and technologies.

b. Automatic processing of data

I, along with my authorized third-party service providers (collectively, “we”, “us”, “our”), may automatically collect data from you behind the scenes and this information is shared with me when you take certain actions. Such information includes, but is not limited to:

whether you open an email from me;
whether you click any links or download a file from the email;
the date you are added to my email marketing platform, and the date you changed any information recorded;
the date you registered for and downloaded a promotional eBook through my delivery system;
a reasonable approximation of your location based on your IP address, the device you use, and data about your browser and software. Note that your use of a Virtual Private Network (“VPN”) may alter the accuracy of the approximation of your location.

c. Privacy Policies of my authorized third-party service providers

While my Privacy Policy describes how I process your Personal Data, my authorized third-party service providers have independent privacy policies, and you should read their policies prior to providing me with your Personal Data through them.

A chart of my current authorized third-party service providers and links to their privacy policies can be found HERE.

d. Cookies

We may also automatically collect certain data from you as you use my Websites by using cookies and similar technologies. Please see my Cookie Policy HERE for more details.

7. DATA I COLLECT ABOUT YOU

There is a wide range of data I may collect to operate my Websites, Services, or both. This information may include, but is not limited to:

a. Information You Voluntarily Give Me.

Personal information you may provide to me includes:

Communications data, such as your contact information—first and last name, email address, billing and mailing addresses, and phone number—and data based on your communications with me. Communications data may be voluntarily provided by you when you register for my Services; or when you contact me through my Services, my Websites’ contact pages, via email, on social media, or otherwise.
Marketing data, such as the contact information you provide when you register to be a VIP Reader and receive my newsletter, volunteer to be an Early Reader, offer to be a Beta reader, or complete a survey. Additionally, details about your engagement with my marketing communications, such as genre preferences, reviewer’s name/handle, reviews, mailing address, age range (i.e., under 18, or 18 and over), and social media handles may be voluntarily provided by you when you register on or engage with my Websites, Services, or both.
Promotion data, such as information you share when you enter a sweepstakes, contest, or giveaway; or when you download a promotional eBook I deliver using an authorized third-party service provider.
Other data not specifically listed here, which I will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

b. Information I Obtain From Others.

I may receive information about you from other sources, including:

Public sources, such as social media platforms and other publicly available sources.
Marketing colleagues, such as other authors who are marketing event or giveaway co-sponsors.

c. Your Personal Data/Information Automatically Collected.

I and my authorized third-party service providers (“we”, “us”, “our”) may automatically log User Data and Technical Data. This information is shared with me and is information about when (i) you interact with my Websites, Services, or both, (ii) you communicate with me, (iii) you use my other online services, or (iv) a combination of the foregoing but not necessarily all, including the following data:

Device data, such as your computer or mobile device’s operating system type and version; web browser type; screen resolution; RAM and disk size; CPU usage; device type (e.g. phone, tablet, computer); manufacturer and model; Internet Protocol address (“IP address”); unique identifiers (including identifiers used for advertising purposes); your Internet Service Provider (ISP), which may also identify your mobile device carrier; general location information such as city, state, country, or geographic area (such as the EU/EEA); date of your interaction; and time zone settings.
Communication interaction data, such as your interactions with my emails or other communications (e.g. whether you open emails or click links within them). We may do this through the use of pixel tags or clear GIFs, which may be embedded invisibly in my emails. I or my authorized third-party service providers may also process other communication data, such as the type of email client you have (e.g., Gmail or Outlook, etc.); the associated operating system; and whether the email was viewed on a desktop, mobile device, or webmail.
Online activity data, such as pages or screens you view; how long you spend on a page or screen; the website you visited before browsing to my Website or Service; navigation paths between pages or screens; information about your activity on a page or screen; access times and duration of access.

d. Cookies and Similar Technologies.

Some of the automatic collection described above is facilitated by the following technologies:

Cookies, which are small data files stored on your device by a website and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and signin status as they navigate a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on my Websites and through my Services.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser, in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a page or email was accessed or opened, or that certain content was viewed or clicked.

For more information on how we use cookies and similar technology, see our Cookie Policy HERE.

e. Non-Personally Identifiable Information.

Personal Data does not include anonymized data. Non-Personally Identifiable Information is information that does not identify a specific User. It’s generally collected when you browse my Websites, Services, or both. This type of information may include things like the Uniform Resource Locator (“URL”) of the website you visited before coming to my Website, the URL of the website you visit after leaving my Website, the type of browser you are using and your IP address. However, when you voluntarily provide your Personal Data, such as by filling out a form, then the information described in this paragraph may be connected to your name, email address, and any other Personal Data you provide.

I may receive non-personally identifiable data from third party analytics providers such as Google; advertising networks such as Facebook, Amazon Advertising Services, or BookBub; search information providers such as Google; providers of technical, payment and delivery services, such as data brokers or aggregators.

8. HOW I MAY PROCESS YOUR CATEGORIES OF PERSONAL DATA

a. Marketing and Promotion

I may use your Personal Data to send marketing and promotions communications to you.

(1) When you sign up as a VIP Reader, I use the information you provide to determine your eligibility to become a VIP Reader and to send you Bella Barwin’s Newsletter by email with the latest author news, bookish events, special promotions, and exclusive excerpts from author Bella Barwin. My newsletter is a form of direct marketing.

(2) If I am running a promotion when you register, your welcome newsletter will provide a link to an authorized third-party service provider so you may download the electronic version of the short story, novella, or other promotion offered. Additionally, when you signup as a VIP Reader, interact with my newsletter, or download a book, my email marketing platforms, and ebook distribution services use your IP address to approximate your geolocation, and use pixel tags or web beacons to determine whether you performed a specific action (see Cookie Policy).

(3) When you sign up as an Early Reviewer or Beta reader, I use the information you provide to determine your eligibility to be an Early Reviewer or Beta reader, to communicate with you about the Early Reviewer or Beta reader process, to distribute advance review copies or Beta reader copies to you, and if you’re an Early Reviewer, to find your reviews online. I may also contact you occasionally with news about Bella Barwin, special promotions, and bookish events.

(4) When you respond to a survey, enter a giveaway, or respond to a promotion, I use the information you provide to administer and analyze the survey, giveaway, or promotion, and may use the information collected to guide my marketing efforts and to communicate with you. If you are the recipient of a giveaway involving a physical prize that must be shipped, then I will also collect your mailing address and possibly your phone number to facilitate shipment.

(5) I process this data to inform you about the books I write and sell, to inform you about other books I think you might enjoy, to engage with you and provide value to you through that engagement, to enable you to partake in my promotions such as giveaways and price reductions, to deliver relevant website content and advertisements to you, to determine which type of stories are of interest to you, to measure or understand the effectiveness of my advertising, and to download backup copies of Personal Data you provide to authorized third party service providers. Additionally, readers have come to desire and expect opportunities to interact with authors, receive behind-the-scenes peeks into the writing process and writing life, and receive news on free or promotionally priced books, among other benefits (without limitation, “reader expectations”).

(6) My lawful grounds for this processing are (i) my legitimate interests which in this case are to study how customers use my Websites, or Services, or both, to develop them, to grow my business, to decide my marketing strategy, to fulfill reader expectations, to direct market, and the data processing I perform is both reasonably necessary and reasonably expected to achieve these legitimate interests, (ii) with your consent, (iii) legal obligation, (iv) vital interests, or (v) a combination of those lawful grounds.

b. Communication Data.

(1) When you communicate with me by using my Website’s contact form, by emailing me, by contacting me through text, social media messaging, social media posting or by using any other means of communication, I may use this data to send you administrative communications, which may include administrative emails, confirmations, technical notices, updates, and security alerts; to respond to your comments and questions; or to communicate with you about events or contests in which you participate. If you are one of my contractors (e.g., editors, cover designers, etc.) or an authorized third-party service provider, I may use your Personal Data in the administration and fulfillment of any contract we may have.

(2) I process this data for the purposes of responding to a communication you initiate, for record keeping, for the establishment, pursuance, or defense of legal claims, to understand your needs and interests, and personalize your experience with my Websites and Services, to provide support for my Websites and Services, and to respond to your requests, questions, and feedback.

(3) My lawful grounds for this processing are (i) my legitimate interests which in this case are to reply to communications sent to me, to direct market, to fulfill reader expectations, to keep records, and to establish, pursue or defend legal claims, and the data processing I perform is both reasonably necessary and reasonably expected to achieve these legitimate interests, (ii) with your consent, (iii) legal obligation, (iv) vital interests, (v) performance of a contract, or (vi) a combination of those lawful grounds.

c. User Data and Technical Data.

(1) I process User Data and Technical Data to operate, maintain, and improve my Websites, Services, or both, to ensure relevant content is provided to you, to ensure the security of my Websites, to maintain back-ups of my Websites, databases, or both, and to enable publication and administration of my Websites, Services, or both.

(2) The source of this data is from my analytics tracking system to help me understand User activity on my Websites, Services, or both, including which pages are most and least visited and how visitors interact with my Websites and Services. I process this data to analyze your use of my Websites and Services, to administer and protect my business and Websites, to deliver relevant website content and advertisements to you and to understand the effectiveness of my advertising.

(3) I have not yet implemented Google Analytics for this purpose but reserve the right to do so in the future. You can learn more about the information collected by Google Analytics by visiting its privacy policy. You can also learn about how to prevent the use of Google Analytics relating to your user activity here: https://tools.google.com/dlpage/gaoptout?hl=en.

(4) My lawful grounds for this processing are (i) my legitimate interests which in this case are to enable me to properly administer my Websites, my Services, my business, or a combination thereof, to grow my business, to decide my marketing strategy, to fulfill reader expectations, to direct market, and the data processing I perform is both reasonably necessary and reasonably expected to achieve these legitimate interests, (ii) with your consent, (iii) legal obligation, (iv) performance of a contract, or (v) a combination of those lawful grounds.

d. Compliance & Operations.

I may use your Personal Data to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities;
protect my, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
audit my internal processes for compliance with legal and contractual requirements or my internal policies;
enforce the terms and conditions that govern my Websites, Services, or both; and
prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

My lawful grounds for this processing are (i) my legitimate interests which in this case are to enable me to properly administer my Websites, my Services, my business, or a combination thereof, to grow my business, to decide my marketing strategy, to fulfill reader expectations, to direct market, and the data processing I perform is both reasonably necessary and reasonably expected to achieve these legitimate interests, (ii) legal obligation, (iii) vital interests, (iv) performance of a contract, (v) with your consent, or (vi) a combination of those lawful grounds.

e. Advertising

I may use Communication Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook advertisements or other display advertisements), so you may discover an author new to you (me!) and learn about my books, and to measure or understand the effectiveness of the advertising I serve you.

The advertising services I use may use cookies and similar technologies to collect information about your interactions with my Websites, Services or both (including the data described in section 7c regarding information automatically collected), our communications, and other online services over time, and use this information to serve online ads that they think will interest you. This is called interest-based advertising. I may also share information about my Users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

See section 9 below, and Cookie Policy, section f, for details about the Meta Pixel.

My lawful grounds for this processing are (i) legitimate interests which is to grow my business, to decide my marketing strategy, to fulfill reader expectations, direct marketing, and the data processing I perform is both reasonably necessary and reasonably expected to achieve these legitimate interests, (ii) with your consent, (iii) legal obligation, (iv) perform a contract, or (v) a combination of those lawful grounds.

f. Cookies

For how I use cookies on https://bellabarwin.com or https://authorbellabarwin.com, see Cookie Policy HERE.

Any websites or landing pages hosted by MailerLink or BookFunnel are subject to their privacy terms and cookie policies, and you should review their policies before using my websites or landing pages hosted on those authorized third-party service providers. I also use the Meta Pixel on my VIP Reader signup pages on Mailerlite, but not on my Early Reviewer signup website.

g. Reasonably Compatible Purposes.

I will only use your Personal Data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email me at info@bellabarwin.com.

h. Automated decision-making or profiling. I do not carry out automated decision making or any type of automated profiling, with one limited automated decision exception. I do not send my newsletter to anyone under 18, and distribution of my welcome newsletter is automated so that only Users who warrant they are at least 18 years old and are not a minor where the User resides receive my welcome newsletter.

i. Non-Personally Identifiable Information

I use Non-Personally Identifiable Information to troubleshoot, administer the Websites, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. I may also share this information with my authorized third-party service providers to measure the overall effectiveness of my online advertising, content, and programming.

You may visit https://bellabarwin.com or https://authorbellabarwin.com anonymously. However, your IP address is logged by my web hosting service for systems administration and troubleshooting purposes whenever you visit the site and I use cookies. If your jurisdiction considers IP addresses as Personal Data, then see User Data and Technical Data for processing justifications. I also use page hits in the aggregate to track the popularity of pages that people visit in order to improve the quality of the site.

Some of my websites use a version of Google reCAPTCHA, which identifies bots by collecting hardware and software information and sending that data to Google for analysis. To learn more about Google reCAPTCHA, please visit https://www.google.com/recaptcha/about/ and https://policies.google.com/privacy.

9. DISCLOSURES OF YOUR PERSONAL DATA AND THIRD PARTY COMMERCIAL OR MARKETING COMMUNICATIONS

I do not sell, trade, or otherwise transfer to outside third parties your Personal Data unless I provide you with advance notice.

a. Advance notice.

This is your advance notice on how I may share your Personal Data with the parties listed or in the circumstances set out below:

Professional advisers including lawyers, bankers, auditors and insurers.
Authorized third-party service providers, the list of which I may, without limitation, alter, delete providers from, or add providers to, from time to time.
Other third parties designated by you where you have provided your consent to do so, including but not limited to, when you enter a contest, giveaway, or promotion I co-sponsor with other authors.
When the release of your Personal Data is appropriate or necessary to comply with the law, enforce my Websites and Services Privacy Policies or Terms of Use or other agreements, or protect my or others’ rights, property or safety.
When using Google Analytics, Meta’s Pixel, or Meta’s successor technology, such as Meta Conversions Application Programming Interface, “Meta CAPI”.
My successors or assigns, including third parties to whom I sell, transfer, or merge parts of my business or my assets, so long as those parties agree to keep this information confidential.

I require all third parties to whom I voluntarily transfer your data to respect the security of your Personal Data and to keep this information confidential. Details on how I do so are in section 15.

b. Disclosures for other parties’ commercial or marketing purposes.

I do not share your Personal Data with any third party for their commercial or marketing purposes, with one known exception:

I use the Meta Pixel, a tool provided by Meta, to track User activity on some of my Websites and Services. This helps me understand how you interact with my site, optimize my advertising campaigns, and personalize your experience. The data collected by the pixel, such as page views and button clicks, is shared with Meta. Meta has a Data Processing Addendum (DPA) that covers the Meta Pixel, including Standard Contractual Clauses (SCCs) for international data transfers. https://www.facebook.com/legal/terms/Privacy

Before I share your Personal Data with any other third party for their own commercial or marketing purposes I will get your express consent.

c. Disclosure of non-personally identifiable data.

Non-personally identifiable data may be provided to other parties for marketing, advertising, or other uses.

d. Third-Party Behavioral Tracking

It’s important to note that I allow third-party behavioral tracking as discussed in this section. See also section f. of my Cookie Policy.

10. MY PROMISE NOT TO SPAM YOU; HOW TO OPT-OUT/UNSUBSCRIBE

I agree to the following for any commercial or marketing messages I send:

Not to use false or misleading subjects or email addresses, and include content labeling when required.
Identify the message as an advertisement in some reasonable way unless the recipient has affirmatively consented to receiving messages from me.
Include the physical postal address for my business.
Monitor third-party email marketing platforms for compliance, if one is used.
Honor opt-out/unsubscribe requests quickly.
Allow Users to unsubscribe by using the link at the bottom of each email.

You can ask me to stop sending you commercial or marketing messages at any time by following the unsubscribe links on any commercial or marketing email I send you or by emailing me with your request at info@bellabarwin.com at any time.

If you unsubscribe and opt out of receiving commercial or marketing communications this opt-out does not apply to Personal Data provided as a result of other transactions, such as purchases, giveaways, etc., that are being processed at the time you opt out, or, if after you opt-out, you opt-in again.

11. APPLICABLE LAW

My Websites are published in the United States, and my Services are provided through authorized third-party service providers in the United States. However, your Personal Data may be processed in other countries by me when I travel, or by authorized third-party service providers I retain in the future.

I attempt to protect the Personal Data of all Users of my Websites and Services, and I attempt to comply with data protection and consumer rights laws to the extent they may apply to my Websites, my Services, or both, but these Websites and Services are located and targeted to United States citizens and my policies are directed at compliance with those laws. If you are uncertain whether this Privacy Policy conflicts with the applicable privacy laws where you are located, you should not submit your Personal Data to me.

a. Governing Law and Jurisdiction

You agree that the United Nations Convention on Contracts for the International Sale of Goods (CISG) is inapplicable to your use of my Websites, Services, or both.

Any dispute arising from or relating to my Privacy Policy, Terms of Use, or your use of my Websites, Services, or both, will be governed by and construed, interpreted, and enforced in accordance with the laws of the state of California and the United States, without regard to conflict of law rules or principles (whether of California or any other jurisdiction) that would cause the application of the laws of any other jurisdiction.

Any dispute between the parties will be exclusively resolved in the state or federal courts of California and the United States, respectively, sitting in Orange County, California. You consent to personal and exclusive jurisdiction in these courts.

b. California Online Privacy Protection Act (CalOPPA) and similar laws in other US states

I do not meet the thresholds to be legally required to comply with the California Online Privacy Protection Act or similar laws in other US states. However, because I value your privacy, I have taken the necessary precautions to protect your privacy as set forth in this Privacy Policy, many provisions of which align with CalOPPA.

c. Children Online Privacy Protection Act (COPPA)

I care about the safety and privacy of children online, and I comply with the federal Children’s Online Privacy Protection Act of 1998. I do not knowingly contact or collect Personal Data from children under the age of 13 on my Websites, through my Services, or both. My Websites and Services are not intended to solicit information of any kind from children under the age of 13. My Websites and Services are all directed to people who are at least 18 years old or older.

If I discover I have received any information from a child under 18 in violation of this policy, I will delete that information immediately. If you believe my Websites, Services, or both have any information from or about anyone under the age of 18, please contact me. See the last section of this policy for my contact information.

12. DATA RETENTION

I will only retain your Personal Data for as long as necessary to fulfill the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, I look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires me to keep basic information about my contractors (including Contract, Identity, Financial and Transaction Data) for seven years after they stop being contractors. In some cases where the transfer of rights is involved, the retention may be permanent.

In some circumstances I may anonymize your Personal Data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

13. THIRD-PARTY SERVICES INCLUDING LINKS AND SOCIAL MEDIA BUTTONS

In using my Websites, Services, or both, you may use third-party services, products, software, plug-ins, embeds, or applications developed by a third-party that are not owned or controlled by me (“third-party services”). Examples include social media buttons and purchase buttons, and you can find links to their privacy policies HERE.

Some of those websites, services, or both are accessed when you click a link on one of my Websites, Services, or both. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

I do not control these third-party websites, am not responsible for other uses of your Personal Data by your social media provider, bookstore, or other third-party service, and am not responsible for their privacy statements. See Terms of Use, section 9, for additional disclaimers.

I recommend you read the terms and conditions and privacy policies of any third-party websites or services that you visit to understand how they collect, use and share your Personal Data, and how you can set your privacy preference on their sites and apps.

14. HOW I RESPOND TO “DO NOT TRACK” SIGNALS

I use an application on https://bellabarwin.com and https://authorbellabarwin.com that is supposed to recognize and honor Do Not Track signals, so to the best of my ability, I Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. However, my authorized third-party service providers may not honor DNT signals, and you should read their privacy policies before using the websites or landing pages hosted by those platforms.

15. DATA SECURITY

I have put in place organizational and technical security measures to prevent your Personal Data that I process from being accidentally lost, used, altered, disclosed, or accessed without authorization.

I also allow access to your Personal Data only to those employees, contractors, or authorized third-party service providers who have a business need to know such data. They will only process your Personal Data for a specified purpose and in accordance with my instructions and they must keep it confidential.

The use of your Personal Data by authorized third-party service providers is also governed by the privacy policies of such parties. My authorized third-party service providers are signatories to the Data Processing Addendum (DPA), including the European Commission’s Standard Contractual Clauses (SCCs) for international data transfers.

However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so I cannot promise or guarantee that cybercriminals, hackers, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

I have procedures in place to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach involving your Personal Data if I am legally required to. Unless applicable laws require an earlier notice, in the event of a data breach I will notify you via email within thirty (30) calendar days and I will also provide notification of such on my site within thirty (30) calendar days.

16. DATA TRANSFER RISK DISCLOSURE AND YOUR CONSENT

a. If you are located outside the United States, you should be aware that your Personal Data will be transferred to the United States.

b. Regardless of your location, you should be aware that your Personal Data will be processed in other countries, union of countries, or unified markets by me when I travel, or by my authorized third-party service providers. The laws of those countries, union of countries, or unified markets may be deemed by your country, your union of countries, or your unified markets to have inadequate data protection.

BY VOLUNTARILY SUBMITTING PERSONAL DATA TO ME THROUGH MY WEBSITES, SERVICES, OR BOTH, OR CORRESPONDING WITH ME VIA ELECTRONIC COMMUNICATIONS OF ANY KIND, YOU CONSENT TO:

(i) the processing of your Personal Data as provided in this Privacy Policy;

(ii) the transfer of that information to, the storage and other processing of that information in, the United States; and,

(iii) the transfer of that information to, the storage and other processing of that information in, other countries, union of countries, or unified markets.

By using my Websites, Services, or both, you grant the above consents, however, in some cases, I’ve asked for your agreement to consent to this transfer by checking a box when you voluntarily provide your Personal Data. You maintain the right to withdraw such consent at any time. If you do not agree to my use of your personal information in line with this Privacy Policy, please do not use my Websites, Services, or both.

c. The possible risk of such transfers to service providers outside your country (or for European Users, outside the EEA) is that your personally identifiable information may not be handled as proscribed by laws governing your data and could increase the risk of release of your Personal Data to unintended persons.

17. NON-US DATA PROTECTION LAWS

I am located in the United States and process data in the United States. Since I travel and work remotely, I also process data in locations other than the United States.

If you are not in the United States, please closely read sections 1 and 2 of this Privacy Policy, along with sections 14 “Data Security” and 15 “Data Transfer Risk Disclosure and Your Consent”, which contain additional important information about international data transfers.

a. International Transfers of Personal Data

Countries outside of the EEA, Switzerland, or the UK do not always offer the same levels of protection to your Personal Data, so European law has prohibited transfers of Personal Data outside of the EEA or Switzerland unless the transfer meets certain criteria. Same for the UK. Australian law and Canadian law also caution against such cross-border transfers.

My business is located in the United States. My authorized third-party service providers are based outside the EEA, Switzerland, the UK, Australia, and Canada so their processing of your Personal Data will involve a transfer of data outside those countries, union of countries, or unified markets. Your Personal Data may be processed in other countries besides the United States by me, or by the authorized third-party service providers I retain in the future.

Whenever I transfer your Personal Data out of your country, your union of countries, or your unified markets, I do my best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

I may transfer your Personal Data to countries that the European Commission have approved as providing an adequate level of protection for Personal Data; or
Where I use authorized third-party service providers who are established outside your country, union of countries, or unified markets, I may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give Personal Data the same protection it has in the EEA.

If none of the above safeguards are available or are insufficient for your jurisdiction, you have consented to the transfer of your Personal Data pursuant to section 16 above. You will have the right to withdraw this consent at any time.

b. European Economic Area (“EEA”) Users, United Kingdom (“UK”) Users, and Switzerland Users

If you are a User in the EEA, Switzerland, or UK, this Privacy Policy satisfies the notice requirements defined in EEA’s General Data Protection Regulation (GDPR) and the UK’s 2025 Data (Use and Access) Act (UK DUA Act), in particular: what Personal Data we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you are an EEA resident, Switzerland resident, or UK resident, your data protection laws (the GDPR or the UK DUA Act) give rights in relation to your Personal Data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://www.dataprotection.ie/docs/A-guide-to-your-rights-Plain-English-Version/r/858.htm

If you wish to exercise any of the rights set out above, please email me at info@bellabarwin.com.

I do not collect any Sensitive Data about website Users as defined by the GDPR or the UK DUA Act. Sensitive data under those laws refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. I do not collect any information about criminal convictions and offenses. In some countries, tax ID numbers are considered sensitive or confidential information, and I do collect those as required by law, such as from my contractors, or giveaway winners over a certain dollar threshold, etc.

If you are not happy with any aspect of how I collect and use your data, I would be grateful if you would contact me at info@bellabarwin.com first if you do have a complaint so that I can try to resolve it for you. If you are in the EEA, you also have the right to complain to the Data Protection Commissioner, the Ireland supervisory authority for data protection issues (https://www.dataprotection.ie/). If you are in the UK, the Information Commissioner’s Office (ICO) is the UK’s authority for data protection issues (https://www.gov.uk/data-protection).

But please, do contact me first if you have a question or concern.

c. Australian Users

If you are a User in Australia, this Privacy Policy satisfies the notice requirements defined in the Australia’s Privacy Act 1988 (Privacy Act), in particular: what Personal Data I collect from you, from which sources, for which purposes, and other recipients of your personal information. I have applied the reasonable necessity test to the Personal Data I process, and this Privacy Policy explains my reasonable necessity for each type of data.

If you do not wish to provide the Personal Data necessary to fulfill their applicable purpose, it may affect my ability to provide you with my Websites, Services, or both, in particular:

Offer you the products or services that you want;
Respond to or help with your requests;
Manage your registration;
Confirm your identity and protect your registration.

At any time, you have the right to request access to or correction of your personal information. See section 18.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner (https://www.oaic.gov.au/) But as always, I’d appreciate it if you contacted me first at info@bellabarwin.com.

d. Canadian Users

If you are a User in Canada, this Privacy Policy satisfies the notice requirement of the Personal Information Protection and Electronic Documents Act (PIPEDA). We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

e. No Waiver; Reservation of Rights

Although the rights and laws of other countries, union of countries, or unified markets are mentioned in my Privacy Policy, Terms of Use, or other policies, I do not waive any rights, affirmative arguments, or defenses, including but not limited to, my right to challenge the application of those laws, regulations, or policies to my Websites, Services, or both, nor are they admissions against interest or proof of any kind that I market to those countries, union of countries, or unified markets. I reserve all my rights, including without limitation, the right to challenge the application of any law, regulation, or policy to my Websites, Services, or both. My mention herein of non-US laws, regulations, or policies is not my consent or concession to legal jurisdiction, venue, authority, or form of dispute resolution, and does not in any way amend or affect the interpretation, construction, or enforcement of section 11, “Applicable Law.”

18. CORRECTING, AMENDING, DELETING, OR OTHER REQUESTS REGARDING YOUR PERSONAL DATA

It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time your personal information changes by contacting me (see last section below for contact information), or change it directly within my authorized third-party service provider by using the links in my newsletter.

If applicable law requires, I will delete your Personal Data upon written request.

If applicable law requires, I will provide you with reasonable access to your personal information upon written request made via email or regular mail. I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In that case, I will notify you.

Unless the applicable law permits me to charge a fee, you will not have to pay a fee to access your Personal Data (or to exercise any of your other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or alternatively, refuse to comply with your request in these circumstances.

To the extent applicable laws grant you access, correction, erasure, restriction, transfer, objection to processing, portability of data and (where the lawful ground of processing is consent) to withdraw consent, I may need to request specific information from you to help me confirm your identity and ensure you are the person whose Personal Data is the subject of the request. This is a security measure to ensure that Personal Data is not disclosed or transferred to, or modified, erased, or restricted by, any person who has no right to receive, correct, erase, restrict, transfer, object to processing, port, or withdraw consent to process the Personal Data. I may also contact you to ask you for further information in relation to your request to speed up my response.

19. ENFORCEMENT OF THIS PRIVACY POLICY

I welcome your comments regarding this Privacy Policy. If you believe that I have not adhered to this Policy or if you have questions regarding this privacy policy, please contact me.

20. CONTACT INFORMATION

My full contact details are:

Bella Barwin, 32565-B Golden Lantern Street #129, Dana Point, California 92629.

info@bellabarwin.com

Or through the contact page HERE.

Effective date 2025-09-14