hey what's going on
welcome to the Doug show I'm duck
hunting ttan and in this episode I'm
going to interview a lawyer all right
it's gonna be very exciting we're going
to talk about GDP our privacy legal
matters just in general for affiliate
marketers and it is my pleasure to
interview Zack streebek and I'm I think
I got the name right I had to ask Zack a
couple times to make sure I got it right
so cool thing Zack is a student of five
figure niche site and that is how I met
him he has a very interesting story I
know a few of my friends that are
lawyers they kind of set out to be
lawyers at the very beginning but Zack
took sort of a was the long path it was
a long path to get to his law degree and
practicing law and all that business and
it's pretty cool pretty cool overall he
talks about dealing blackjack and some
other things along the way so very
interesting overall so I'll send it to
the interview in just a second here but
after the interview I will talk about
some of the legal stuff that I have been
through at least you know running
haven't been sued or anything thank
goodness but and I haven't had to sue
anyone else also thank goodness but I
will mention a few things that you know
I dealt with either with setting up a
business the accounting area which by
the way all this stuff I am generally
uninformed I don't know what I'm talking
about but I can tell you about my own
personal experience and if you need
specific advice I highly recommend you
get your own lawyer to get information
or get an accountant for those you know
accounting and tax questions you may
have
sometimes you need to talk to both of
make sure they're telling you the right
stuff I've gotten I'll get to those
stories later so anyway Zack has some
pretty awesome information for us and if
you do have
questions probably bring Zach on to
field some of those questions again I
don't know what I'm talking about
but Zach does so if you do have
questions you could shoot me an email at
feedback at Doug dot show and without
further ado let's get to the interview
hey what's going on it's doug Cummington
here and I'm with Zach streebek did I
get the last name right that's correct
awesome awesome so Zach is my lawyer
friend and for people that don't know
you Zach can you give a little intro
sure my name is Zach streebek I am a
lawyer most of my practice involves
video games and board games and websites
and mobile apps and things like that
sort of a new media type thanks but
mostly I'm known as a video game at a
board game lawyer but I'm also mostly a
niche site owner having done Doug's
course so that's how I kind of got
involved because all that's very cool
and how did you find your way into the
like game area of loitering because that
sounds more interesting than some of the
other lawyer stuff that you could be
doing right most lawyer is pretty boring
although being a game lawyer is also
boring it's just doing something a
little more interesting I used to be a
game developer so I used to do animation
and game design for for children's
computer games a long time ago and so as
I transitioned out of that career and
into a new one I decided to choose video
games and board games as my my practice
focus my client focus gotcha so you you
were like a game designer and then went
to law school after that correct yeah
cool so how long I wasn't a very good
game I wasn't gonna very good artist so
I'm a better lawyer that I am an artist
that guys I think I found my calling
while still staying in the same in the
same industry gotcha
so can you this is sort of off from the
topic though we're gonna cover but I was
hoping that we would find a thread like
this so how did you
I end up deciding because law school is
assumed not cheap it takes a lot of time
it's not easy right so how like how did
you figure like hey I'm gonna quit my
job take a detour and just like change
things up well I got laid off from the
game company I was working at at one
point so I'm sure you you kind of have a
shared experience there and I
transitioned into a second career which
is working in casinos so I was a
blackjack dealer for about six years and
while I did that I hated it you know you
talk about repetitive work we're sort of
just doing the same thing over and over
again all day hated that so while I was
there I started to get it I got another
bachelor's degree in history and decided
to go to law school after that during
law school I didn't didn't work but
after school ended and I graduated
passed the bar I started my my own solo
practice like the next day and went
digital nomad for three or four years
after that sort of traveling world
running it virtually gotcha
that's pretty cool so you did the
blackjack dealing for six years you said
so where were you located for that near
Palm Springs California so outside of
Los Angeles I started off in Coachella
people know Coachella now because it's
like Katella music festival which when I
was there it didn't exist yet I don't
think but uh I was at a trump Trump
casino out there and then I moved inward
a little bit toward Palm Springs and and
started working yeah working there okay
interesting super interesting and then
from the so you got a second bachelor's
degree in history and did you know that
you were going to go to law school I
know history is sort of like one of the
very common for lawyers is the rewrite
that's why I did it that's why I picked
history I was also interested in it
personally
however I mean knowing what I know now I
probably have done some sort of science
as you can you can't be a patent
attorney so I can't write patents or
deal with patents unless I have some
sort of science or technical
which I probably could have done but I
didn't screw interesting yeah I knew
actually a couple actually I guess I'm
not good friends with him now but a
couple good friends and one guy went to
high school with he got a double e
degree ended up working at the Patent
Office and I think he eventually got his
law degree and it's like me and that's
it that's a pretty good combination of
like technical skills and like cool
stuff yeah then there's a lot of earning
potential there yeah there was this
other dude who he got an Emmy degree and
then he had his master's and then his
law degree and ended up like as a like
IP and patent and like was doing stuff
with Google and like it was kind of
great like once you see the path it's
like oh wow that's amazing
so exactly anyway so the reason why
we're talking is to sort of get into the
legal areas that people that have
affiliate sites or niche sites are
making money online with websites should
be concerned about so I have sort of a
like list of a couple topics that are
pretty common questions that I have and
generally I think most people are
similar to me in that we don't know much
about laws or what we're actually
supposed to do so we kind of try and do
our best but probably make a ton of
mistakes so let's start with a couple of
the very basic things which is around or
which are around not sure I can't
remember what I said there but basically
disclaimers and like the FTC so for me
as I'm doing more affiliate marketing
mentioning more products I am basically
probably overdoing it and just saying
like I feel like I'm I'm affiliated with
them I get a commission like if you buy
blah blah blah like I'm mentioning at
the beginning at the end making it super
clear in plain language so just from a
high level what do people need to know
about the FTC disclaimers and mentioning
affiliation that sort of thing right
well I mean you
so I'll preface this by saying the FCC
actually has some great documents online
on their website so if you look up
endorsement guidelines they have some
documents that you could read that are
pretty plainly stated and give some
examples but there have definitely been
some lawsuits if you're a niche site
owner an affiliate site owner it most
likely the FTC is not gonna come after
you because you're just too small
so most of the brands that people the
FTC have come after have been like
fashion brands that have done Instagram
contests where they have people doing
hashtags but they're not disclosing that
they're sponsored things like that
however it doesn't hurt to be to be
compliant with the law so it's good to
familiarize yourself with it I mean
generally you want you want to assume
that people aren't gonna read past where
they're gonna be clicking the affiliate
link and I know that you've talked about
this before and you you put your
affiliate disclosure up near the top
which is good because they're guaranteed
to see that right but if you put it in
your sidebar if you put it down in your
footer if they're looking on mobile you
know they're gonna they're gonna be
seeing 20 affiliate links by the time
they get to you know your sidebar starts
at the bottom and then your footers
below that so they're not going to get
your disclosure so arguably you're not
doing it correctly because you're not
really giving them notice that these are
sponsored links right and you can use a
hashtag you can use a you know hashtag
affiliate hashtag sponsored something
like that or just a little notice that
like you use that says you know these
these are affiliate links I make a
little bit of money you know if you put
it in plain language and you know you
say it in a way that makes them want to
support you you know help to support the
site I get a little bit from from when
you click these links and buy something
right and even you know some people with
this this doesn't cost you any more but
it helps us to keep the site that kind
of thing but as long as it's in plain
language and it's in sort of
commensurate with where the affiliate
link is I think that's that's the best
way you're gonna do it that's the way
the FTC is gonna gonna tell you to do it
as well cool
so and I want to go back to a part that
you mentioned where if you put your
disclaimer or actually anything in your
sidebar probably anyone on mobile is not
gonna see and the reason why and you
alluded to it but just want to like
underscore it so for mobile responsive
site typically the sidebar is going to
be placed under the content nowadays so
yeah like you said they maybe wouldn't
see it they wouldn't scroll all the way
down and depending on I mean some of my
pages are so long I wouldn't expect them
to scroll down 25% of it you know let
alone get to the very bottom and I guess
the spirit of the law is to let the
person know if they click the link that
you're going to get a commission and
you're affiliated they're like so if
it's in the bottom then the spirit of
the law isn't like I don't know what I'm
trying to say but like the spirit of the
law is respected the law wants once the
user to know that you have a vested
interest in them clicking that link
right so it's not like a hundred percent
free choice that you've decided on these
products or that you know you're doing
it out of the goodness of your heart
they want to know that there's there's a
financial incentive there and then the
user can can make that decision however
they want but they also want what you're
getting at
they want a viewer that's seeing that
link to also be aware of the fact that
it it is a an affiliate link response
earth link at the same time indeed so
anything else around the disclaimer or
anything like that before we shift gears
a little bit here the FCC I gave some
examples but the the endorsement
guidelines actually do give some
examples of what they would be and if
you're doing social media posts it's the
same thing so if you're putting you know
you you do your your deal of the day or
your product of the day or something on
your on your Facebook page or whatever
that's connected with your affiliate
site you know you're supposed to do an
affiliate hashtag or a sponsored hashtag
or something like that you can you know
there are specifics like it can't be
hashtag AFF or hash tag you know like
really shortened versions of it it's
really supposed
whole word and honestly those are all in
the in the guidelines they've kind of
covered that excellent yes I've actually
read those so we'll put links and stuff
so people can go check those out and
like you said Zach it's like pretty
readable like for normal people to
understand with examples it's like kind
of hard to goof up yeah unless you're
not following it sir and as we're going
through this I realize that legal stuff
is boring so we're gonna mix it up and
we're gonna do some like we're gonna do
some content we're gonna do some other
like off-topic stuff so you went digital
nomad for a few years can you talk about
that some because this is a dream of
many many people and it sounds like you
had a kind of a an unusual path through
your career and in general so how was
the digital nomad stuff how did you
figure out to do that I got into it
based on like many nomads the the 4-hour
workweek when I read that I think it a
mentor of mine had recommended the maybe
was the tropical mba podcast and they
kind of turned me on to the 4-hour
workweek so I read that and all that was
and the mentor had been a solo attorney
as well and all that sort of came
together and made me think hey I can
start my own business I can run it from
everywhere you know I just I don't go to
court as a lawyer I draft contracts and
do a lot of transactional work and deal
with intellectual property so I don't
need to be anywhere so as long as I'm
awake in the right time zone you know I
can I can do the work from anywhere so
it's actually kind of funny because for
the first year or so there really wasn't
enough money coming in from clients
because all my all my clients are are
coming from content marketing so just
like just like you guys you guys us with
the affiliate sites you know I write
blog posts and the blog posts bring
people in I write guest posts and the
guest people best post bring people in
all of that stuff I kind of did it
intuitively I'm getting better at it as
as I learned actually learned for from
you and firm from
affiliate site SEO type people but in
the beginning was just creating content
and getting out there and to make money
I did writing for other blogs and sort
of content creation I work for text
broker so I was basically doing whatever
their slave wages are for their
four-star writers it's it's not much so
you know we kind of had a sidebar before
we were start recording it's about you
know how much you can actually make or
how much you need to pay writers so that
they can actually live and you know if
you live in Bangkok like I was or around
Southeast Asia
and I lived in Mexico for a little while
you know I travel around the cost of
living is pretty cheap but you know you
you need to work I needed to work about
three or four hours a day writing text
broker blogs and then I could afford to
live and spend the rest of my time
trying to grow my business gotcha
and how long ago was that 2014 so the
beginning of 2014 is when I started my
business so for the first year I was
probably uh yeah that was that was fully
nomadic and spending a few hours each
day I was I was fortunate enough because
I had legal training I could get on a
legal team on text broker and they had a
steady supply of work coming in all the
time so it was always something but it
was you know $7 a post or something like
that you know or you just have to crank
him out and like 90% of it is and this
is this is writing for legal blogs and
this is one of the crazy things like
legal blogs have the worst content it
was basically like you take a car
accident story and you'd rewrite it and
then put a little blurb about you know
what you do how call a lawyer if you
have a car accident in a river I mean
you want to talk about like the do's and
don'ts of creating good content this is
like this exposed me till the worst kind
of content which just like trash to fill
up a blog right but there was just
hundreds of these posts available right
so you know you just write them I'd
write about someone some celebrities
divorce ten times and just sort of write
the same post in slightly different ways
so many times just ridiculous this
terrible man so like that was for about
a year you said as things were ramping
up for your business
and then over time you started like
bringing in like legal clients to and
you had a steady stream so you didn't
have to do the text broker gig I
remember the day the feeling when I
thought I don't need to write these
stupid things anymore I'm done and you
know I just had enough money coming in
for my my business that that it was it
was fine and I know a lot of affiliate
site owners probably have the same thing
you know you have that number you need
to hit and when you do it's like alright
I don't need to do this full-time job
anymore I don't need to do whatever else
I'm doing to make money I can I can just
let the website work
right on so before you left on your your
you know your travels and stuff did you
save up like a nest egg or something
like that or you were like I'm just
gonna pull the plug and I'll do the text
broker thing I sold my car on Craigslist
I put it up there and an hour later some
guy showed up with $4,000 in cash and
bought it and some shady business with
you know signing it to his uncle or
something like that but I didn't really
care like it was done and I was out and
so yeah that $4,000 got me the first you
know few months in in Thailand and the
plane ticket and you know the money was
coming in slowly but surely so that kind
of kept me going I mean it was it's
tight living I know that but if you save
up more you know you say about $10,000
or something like that you can live
around in Southeast Asia for for about a
year probably as long as you don't get
kicked out for Reason reasons gotcha
wow this is crazy yeah like we we sort
of traveled around in the US a little
bit but like me to be like the opposite
we went to like expensive cities and
rented like expensive houses and stuff
yeah so you know teach their own
different lifestyles yeah now I'm work
I'm more able to do that cuz I actually
have a decent business but yeah was
living on the cheap right and we like I
was gonna say we had a dog that we
wanted to bring with us so that's this
part of the the reason so anyway back to
the topic and back to the boring stuff
so let's talk about gdpr and I remember
it was I guess like a year and some
change ago I kept seeing all this
information coming out Aweber was
sending me stuff other companies were
sending me information I was getting all
these notices and then I was like what
is this fucking stuff going on so can
you explain what is gdpr what does it
even stand for why do we care it's the
general data protection regulation I
believe it applies to EU residents which
can be people who live in the EU now are
also EU residents that are living abroad
so it's pretty wide ranging and that's
why people were freaking out about it
because even if someone's in the US if
you're taking their email address
without their consent or something like
that you're technically in violation so
you know everyone updated their privacy
policies cuz you need to alert people
they have a certain amount of Rights
that are free so a right to see what
information you have on them a right to
delete that information or right to not
be just various things and so yeah
people were going nuts
the big thing is you know with it with
an affiliate site I mean there's a few
things that you specifically need to
think about the big one in the
background is data security and making
sure that any proximal information that
you're getting for people is sort of
secured in a lot of these third-party
services that we use are probably gonna
have better data security than if you
had you know a server in your in your
house or something like that right I
mean they they have they use Amazon Web
Services that's like you know in a
special place with security guards and
all that so everything's encrypted you
know that's great you know you use SSL
encryption on your side that kind of
stuff that's good the other thing is
getting consent when you take personal
information so this is why a web or and
MailChimp we're sending out these emails
that you know give you TDP our tools and
things like that because you cured you
know someone's email address in the
first name and last name phone number or
whatever you take from them that's all
personal information
that you need to make sure that you have
either consent to get it or there's
actually six they call them lawful basis
for taking and processing that
information with a mailing list like
that consent is gonna be the number one
so basically it's like you know they
have to know when they're putting their
email address what they're signing up
for so if you kind of lie to them and
say you know we're gonna send you this
but actually you're putting them on a
mailing list or sending that information
to someone else or things like that you
can't do that so you didn't only really
take use it for the purpose that you
include them into but if you've got
people and you know when you're playing
about you know sign up for the
newsletter and I'll send you this free
lead magnet and you really didn't have
any problems before gdpr and so they
were kind of freaking out about nothing
you were already compliant cuz you were
already getting consent and that consent
is recorded with MailChimp or Aweber or
convertkit or whatever you're using so
it wasn't a big deal the big deals are
things like if you use Google Analytics
let's say you know you need to disclose
that you're using bad and that's taking
certain personal information like their
IP address and and things like that you
know their location that kind of stuff
so you know usually a privacy policy
should have all this stuff so you
basically do it do an inventory what
information am i taking from them how am
I using it and who am i sharing it with
and you need to disclose all that stuff
in your privacy policy and I suspect
that most and probably even on my
affiliate sites that is not properly
doing all that so it may be worth taking
a look at that now you know again most
of our sites are so small even when
they're big sites they're still so small
that no one's ever gonna notice that no
one's ever gonna care but again it's
good to be compliant regardless and and
just keep yourself safe got it so the
the main idea is to make sure you have
consent whenever someone's like
providing some information and to give
them the ability to like see what it is
and delete it if they want to get they
need to be able to opt-out - which is
good again you know because the can-spam
act already required that in your emails
needs to be something at the bottom the
email that they can unsubscribe so if
you're already using one of these
services they're all going to be forcing
you to comply with that so it should be
fine
cool and the one thing that I changed
like for an insight project not for any
of my affiliate sites is the you
actually mentioned it so like Wilson do
the lead magnet but I also needed to add
this is one thing that I went through
all my opt-ins and it was like I'll send
you a few emails a week because
sometimes I do send more than one and
then ascend promotional emails as well
to let them know yeah you're gonna be
sold to at some point because I think
that you know I wanted to make that
clear
I'm gonna sell to you at some point and
you're gonna get information but I'm
gonna sell you something yeah and some I
know MailChimp does it because I use
MailChimp for my business they'll allow
you to do kind of a GP our compliance
set up where they can select different
types of emails and they're put into
different segments so they can select I
just want the newsletter I want the
promotional emails I want this and that
and you can categorize them in different
ways so that you can make sure that
you're not sending them things they
didn't agree to which is good I mean if
you want to be like a hundred percent on
the on the level with gdpr having having
that kind of granularity can't hurt but
again I don't know it depends on and
this is sort of the more advanced
affiliate site stuff because a lot of
the the newer sites aren't doing mailing
less and aren't even bothering with this
stuff so it's yeah okay so I guess a
little bit deeper on this like for the
average person like mmm you let's say
they have a pretty big website let's say
they're getting you know a hundred to
two hundred thousand visitors per month
or something like that like you know
could they like actually be sued through
like violations with gdpr
potentially so what happens is a user
will complain to one of the data
protection authorities in Europe and
each country and EU has their own so
let's say they send a complaint to the
German authority the German Authority
will then you know
review it and see if there's something
there and they could either assess a
fine which so the big freak out when GPR
was coming out was that the fine could
be up to 4% of your your global revenue
or something like that like it was you
know for bigger companies it was like
some insane number now they haven't been
that high even the day one complaints
against Google and Facebook and all them
were I think Google something like 50
million euro which if your Google isn't
really that much and it's because they
were not disclosing things about
personalized ads and so the personalized
ads is the bigger thing I think taking
email addresses for a an authority site
probably is lower on their list but you
think there's places where you can
actually look at what the judgments
under GAAP are have been and you can see
if there's similar sites to you on there
but it would it would require that
someone complains your users would
complain first and then the authorities
will look into it and you don't you
don't get sued under DDP are you you
just sort of it's like a government
complaint process administrative process
oh but they can impose fines on you so I
mean there is danger of a fine I suppose
okay and then final question for GBP are
here they you know I land on these web
sites and then I see that little pop up
and it's like we're using cookies and
blah blah blah you have to consent and
all that and it's like the worst user
experience it's like the dumbest thing
yeah ever and I don't do it and I'm like
yeah I hopefully no one complains with
me on my soapbox but I'm just like you
know what like don't come to my website
it's a very like self-centered way to
approach it
okay suppose right I'm just like hey
yeah look you use the Internet
you're getting free stuff yeah yeah
thank you for that yeah yeah I
understand there are certain cookies you
don't need to disclose and then there
are others that you do so there's a list
it's actually this wasn't from gdpr this
is from there's an EU cookie law cookie
directive that came before this actually
and so that's where you're getting the
the cookie stuff from and why you need
to agree to it and a lot of it is like
if they're tracking you from one site to
another and things like that which may
be the case I'm not sure how Amazon
affiliate works that maybe a cookie that
is the kind that you need to disclose
and again you know even on my own sites
I would freely admit that I'm not I'm
not kind of in full compliance with this
you know I worry about my business but
not necessarily and sites aren't big
enough that you know they're even a
anything worth worrying about but it's
one of those things as you get bigger
that's the kind of thing you should
start to to think about you know are you
doing your problem and I understand I
agree it's a terrible user experience
these things pop up on every site and I
swear even if I clicked it one day I
feel like it's coming back another day
and there are there are some standard
JavaScript things that you can add to
your to your sites
I think there's open cookie something
where you can have them do that and just
get that okay on there but still yeah
you're right it's a terrible user
experience right it's a lot
fortunately it's the law they don't seem
to care yeah it's funny like because I
was revamping my site like trying to
work on speed and stuff and I was like
okay I'm not gonna I'm not gonna like
just hose everything down now and make
it so no one can read anything I know
there's other ways to handle it but
that's my interpretation absolutely this
is dumb which is not what you're
supposed to do with laws and everything
but well that's just where I ended up on
it
okay shifting to the more interesting
topic and then we're gonna do this back
and forth thing yes so how did you get
into like the affiliate sites like you
mentioned you you were a student if I
figured a niche site so how did you like
find your way into it remember it's a
good question so I okay before I even
started the digital Nomad thing one of
the things I started doing was making I
had found they were Empire flippers then
wait are they still at they were Adsense
flippers back then right there Empire
flippers now is that EF they have a
different name yeah yeah Empire maybe
empire they've like continued to general
yes well now there are now there a
website flipping place right he used to
be that they were like they were telling
you how to do adsense websites and
things like that so I get a bunch of
terrible websites that were just like
you know I was like put him up and
putting up like 200 word blog posts you
know trying to get and I had no idea
what I was doing and then I was trying
to do like drop shipping stores and all
this nonsense and I didn't understand
any of it eventually I joined this group
the tropical and VA has a dynamite
circle I don't you know what that is
it's like they're a little sort of
mastermind or you know group for sort of
serious business people I joined that
and I met Dom Wells through there and I
saw that he was doing he's done for you
web sites so I ended up buying two of
those which you know I probably it was a
mistake it was just more than I get
handle right probably one would have
been a better a better deal cuz actually
one of those is still sort of sitting
there and I haven't gotten back to it
cuz I ended up starting another excite
with with your course as well because I
think through Dom he had done some
training that mentioned kgr stuff and
then I ended up looking that up
and I saw your video and ended up buying
your course and getting into it from
there so that's my affiliate slate
journey as opposed but yeah it started
off I mean they were a complete disaster
and I still have it's funny I'm reminded
all the time because they're all still
in my Google Analytics all the sites
that don't even exist anymore but I
could see all the names of it and it's
like my my blood pressure monitor or
something that's dumb like that where
it's like some very hyper specific thing
that you know it's just a terrible and
they're all dot info or dot you know
some crazy just there but I'm sure you
you know that as well I didn't have a
story like you where they made a lot of
money in the beginning I made zero money
off that in fact I got my adsense
account banned like day one when I tried
putting ads on these things and then
yeah I still haven't reinstated it
especially yeah well it's like for
people that don't know and maybe they
got into this like in the last couple
years or something like that I mean I
got star
around the same time as you 2013-2014 in
absence flippers yeah I remember
downloading their free ebook it was like
70 pages on how to start it's not long
time pro all this no yeah yeah I'm like
so many of the like you know Empire
flippers big marketplace they're pushing
I don't know how many millions of
dollars through and they're you know
they have a big reach and it's just
amazing cuz they literally started with
these generally regarded as crappy sites
small absence sites and they what they
did was they figured out how to just
systemize it systematize it and like
build a bunch of him and realized well
we could sell them so that we're you
know Empire flippers right so they were
flipping there's Adsense sites as they
were building them and actually like Dom
started doing that at human proof
designs and it like he wasn't with
Amazon affiliate sites which they're
still doing and they're they've gotten
better over time so it's kind of crazy
like people started at a certain point
just like their trajectory is pretty
amazing if they stuck with it so what
they what they sold me was the dream of
having an empire of sites that I can
sell and flip and and make money from
which hasn't quite happened yet
especially with the Adsense stuff I'm
working on it so in in quick quick
correction so I had probably eight sites
that were not very good but I just did
them really quickly and then within a
year like I had one or two like
successes and I quickly got penalized
after that so I mean it was kind of a
rollercoaster ride across the board so
anyway it's perfectly normal everyone to
have just a mess of a wake of failed
sites behind you so that's that's how
any business works really you have to
you have to fail and learn to walk
before you can run right I mean you're
not gonna get a big right out of the
gate Indy usual indeed okay now moving
back to the boring legal stuff so no
offense is active but privacy policies
so what should be in a privacy policy do
you have like a sample like what high
point should we hit here because I don't
I
now yeah it's the same as same as when I
was talking about gdpr I mean that's
basically what sort of dictating privacy
policies now there's a California law
that's going into place in 2020 so the
beginning of 2020 however again for most
smaller sites it's not gonna apply it's
it's a question of if you meet certain
thresholds like it's like fifty million
dollars in sales or something like that
or a certain amount of users fifty
thousand users or something like that
which could could hit some site in
California and so if you're not hitting
these numbers then you don't need to
worry about it and then if you're not
doing certain things it doesn't matter
so generally if you're meeting the TV PR
rules you're gonna be hitting the
California rules as well if your site's
big enough that you're actually worrying
about this then that's you're gonna know
and you're gonna you should look into it
I have a post on my site we could
probably link to that somewhere but yeah
so what do what do you need what
personal information you're collecting
whether it's directly from the user like
when they sign up for a mailing list or
through something like google analytics
or if they sign in sign in through a
facebook login or something like that
you need to disclose I'm taking this
information which means I could take
your age your you know your name blah
blah blah your friends your profile
picture that kind of personal
information and then what do you do with
it why do you use it each of that each
of those things what do you use it for
you know I use your my email address in
your first name and last name to deal
with technical support issues customer
support issues to deal with you know to
send your newsletters and run contests
or whatever you do and then who else do
you share it with so if you're you get
the email address but then you share
with MailChimp or with Aweber you need
to disclose that who you're using and
then basically link to their privacy
policy because they're you know then
their privacy policies can control so
this document is mostly a disclosure
document you want to disclose how you're
doing all this stuff it doesn't there's
not necessarily a limit to what you can
do DDP are put does put some limits on
it you know especially it needs to be
under a lawful basis so I'll go through
those I've mentioned the lawful basis
thing earlier but consent is one
if you have a contractual relationship
so let's say they buy something through
your site you're selling your own info
product and you need to get their
payment information and all that well
the basis for taking that information is
a contract right you are buying this
thing and I am delivering it to you it
could be a if you're required by the law
to give this up so let's say you know
you need to provide this to the
authorities all the logins from your
website or something like that and
you're required by law to do that there
is something called legitimate interest
which is basically a catch-all for other
things where it's basically my interest
in taking this information outweighs
your interest in having privacy
basically that's that's and that sort of
B we couldn't find another place to put
it so we're gonna stick it into
legitimate interest and that's sort of
one that hasn't really been hashed out
by the legal stuff by the complaints and
in the regulatory authorities there's
some some guidance on it but it's not
really a hundred percent it's a lot of
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