Last Updated October 10th, 2020
INFORMATION THAT WE COLLECT
Personal Data: Personal Data is information that can be used to identify you specifically, including your name, shipping address, email address, telephone number or demographic information like your age, gender, or hometown. You consent to giving us this information by providing it to us voluntarily on our website or any mobile application. You provide some of this information when you register with or make purchases from our website. You may also provide this information by participating in various activities associated with our site, including responding to blogs, contacting us with questions, or participating in group training. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website or from making purchases.
Derivative Data: Derivative data is information that our servers automatically collect about you when you access our website, such as your IP address, browser type, the dates and times that you access our website, and the specific pages you view. If you are using a mobile application, our servers may collect information about your device name and type, your phone number, your country of origin, and other interactions with our application.
Social Networking Data: We may access personal information from social networking sites and apps, including Facebook, Instagram, Linked-in, Twitter, Snapchat or other social networking sites or apps not named specifically here, which may include your name, your social network username, location, email address, age, gender, profile picture and any other public information. If you do not want us to access this information, please go to the specific social networking site and change your privacy settings.
Mobile Device Data: If you use our website via a mobile device or app, we may collect information about your mobile device, including device ID, model and manufacturer, and location information.
Other data: On occasion, you may give us additional data in order to enter into a contest or giveaway or to participate in a survey. You will be prompted for this information and it will be clear that you are offering this kind of information in exchange for an entry into such a contest or giveaway.
Collection of Data
Our site uses technologies of third-party partners [such as NextRoll] to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, [NextRoll/these partners] collect information about your activity on our site(s) to enable us to:
Measure and analyze traffic and browsing activity on our site(s);
Show advertisements for our products and/or services to you on third-party sites;
Measure and analyze the performance of our advertising campaigns;
We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with [NextRoll/ our advertising partners]. This allows our partners to recognize and deliver you ads across devices and browsers. To read more about the technologies used by [NextRoll/our partner] and their cross device capabilities please refer to NextRoll’s Privacy Notice.
Our partners [such as NextRoll] may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason you can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:
HOW WE USE YOUR INFORMATION
You information allows us to offer you certain products and services, including the use of our website, to fulfill our obligations to you, to customize your interaction with our company and our website, and to allow us to suggest other products and services we think might interest you. We generally store your data and transmit it to a third party for processing. However, to the extent we process your data, we do so to serve our legitimate business interests (such as providing you with the opportunity to purchase our goods or services and interact with our website or mobile app).
Specifically, we may use the information and data described above to:
Create and administer your account; and
Deliver any products or services purchased by you to you; and
Correspond with you; and
Process payments or refunds; and
Contact you about new offerings that we think you will be interested in; and
Interact with you via social media; and
Send you a newsletter or other updates about our company or website; and
Deliver targeted advertising; and
Request feedback from you; and
Notify you of updates to our product and service offerings; and
Resolve disputes and troubleshoot any problems; and
Administer contests or giveaways; and
Generate a profile that is personalized to you, so that future interactions with our website will be more personal; and
Compile anonymous statistical data for our own use or for a third party’s use; and
Assist law enforcement as necessary; and
Prevent fraudulent activity on our website or mobile app; and
Analyze trends to improve our website and offerings.
WHY WE DISCLOSE YOUR INFORMATION
The following are specific reasons why we may share your information.
Third Party Processing: We may disclose your information to third parties who assist us with various tasks, including payment processing, hosting services, email delivery and customer service. We may not always disclose these third party processors if not required by law.
By Law: We may share your data as required by law or to respond to legal process, including a subpoena, or as necessary to protect the rights, property, and safety of others. This includes sharing information with other parties to prevent or address fraud and to avoid credit risks.
To Protect Our Company: We may use your information to protect our company, including to investigate and remedy any violations of our rights or policies. We may also disclose your information as reasonably necessary to acquire and maintain insurance coverage, manage risks, obtain financial or legal advice, or to exercise or defend against legal claims.
Third Party Partners: In order to provide our services and administer our rewards and promotional programs, we may share your information (excluding Financial Data) with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs. With your permission, third-party applications or services may access your Personal Information. We use standard OAuth (open authorization) to enable you to give permission to share your Personal Information with other websites and services, such as Facebook and Twitter (e.g., when you agree to a pop-up requesting you to allow another application to access your account information). We also use OAuth to allow us to share information about you that is stored by us without sharing your security credentials.
We may also employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, order fulfillment, customer services, and marketing assistance. These other companies will have access to your data only as necessary to perform their functions and to the extent permitted by law.
Additionally, we may disclose your information to certain third parties (as listed on our website) for the purpose of enabling them to contact you so that they can offer you relevant goods and services.
Advertisers: We may use third party advertising companies to run and manage our ads, such as Southern Sass Group, LLC DBA System Envy to produce ads that appears when you visit our Website or mobile app. These companies may use information about your visit to our website and other websites that are contained in web cookies (as described below) to offer you personalized advertisements about goods and services that might interest you. We cannot control the activities of such other advertisers or web sites. You should consult the respective Privacy Policies of these third-party advertisers for more detailed information on their practices as well as for instructions about how to opt-out of certain practices.
Other Third Parties: We may share information with advertisers, our investors, or other third parties for the purpose of conducting general business analysis. If we do so, we will make reasonable efforts to inform You if required by law.
Interaction with others: If you interact with others on our website or mobile app, such as participating in a group chat or a group online course, other users may have access to some of your data, including your name, profile picture, and your history of interaction with our website, such as prior comments or posts.
Online postings: When you post online, your posts may be viewed by others, and we may distribute your comments outside the website.
External Links: Our website may include hyperlinks to other websites not controlled by us. We suggest you exercise caution when clicking on a hyperlink. Although we use reasonable care in including a hyperlink on our own web page, we do not regularly monitor the websites of these third parties, are not responsible for any damage or consequences you suffer by using these hyperlinks. We are not bound by the Privacy Policies of any third party website that you access by a hyperlink, nor are they bound by ours. We encourage you to read the Policies of those third party websites before interacting with them or making purchases. They may collect different information and by different methods than we do.
Other purposes: We may disclose your personal data as necessary to comply with any legal obligation or to protect your interests, or the vital interests of others or our company.
Cookies, Log Files and Web Beacons: Like many other Web sites, we make use of log files. These files merely log visitors to the site – usually a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks. This information is used to analyze trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses and other such information are not linked to any information that is personally identifiable.
PROCESSING YOUR INFORMATION
For the most part, we do not process your information in-house, but give it to third party processors for processing. For example, when PayPal takes your payment information, they are a third party processor. They process your payment and remit the funds to us. So in many instances, it will be necessary for us to transmit your information to a third party processor, as we do not have the capability to perform these functions. More detail on third party processing is provided below.
However, we may, from time to time, process your data internally. The legal basis for this processing is both your consent to the processing, and our need to conduct our legitimate business interests. Our purposes in processing this information, if we do, is to administer, maintain, and improve our website and offerings, to enter into contracts with you, to fulfill the terms of those contracts, to keep records of our transactions and interactions, to be able to provide you with goods and services, to comply with our legal obligations, to obtain professional advice, and to protect the rights and interests of our company, our customers (including you), and any third parties. We may process the following data:
Data associated with your account, such as your name, address, email address and payment information.
Data about your usage of our website, such as your IP address, geographical information, and how long you accessed our website and what you viewed.
Data related to your personal profile, such as your name, address, profile picture, interests and hobbies, or employment details.
Data that you provide us in the course of using our services.
Data that you post on our website, such as comments or responses to blogs.
Data that you submit to us when you make an inquiry regarding our website or offerings.
Data related to your transactions with us, including your purchase of our goods or services. This information may include contact details and payment information.
Data that you provide to us when you subscribe to our emails or newsletters, including your email address and contact information.
Data that you submit to us via correspondence, such as when you email us with questions.
Any other data identified in this policy, for the purpose of complying with our legal obligations, or to protect the vital interests of you or any other natural person.
Our website is hosted by servers located in the U.S. Therefore, if you reside in the European Union, some of your data will be transferred internationally to those servers. Transfers will be protected by appropriate safeguards, namely the EU-US Privacy Shield. More information on the Privacy Shield can be found at: https://www.privacyshield.gov/welcome.
We use website hosting servers and third party processors located in the United States and Canada, which have received an Adequacy Determination from the European Commission, meaning that appropriate safeguards are in place to protect data once it is transferred to that country.
We retain personal data as long as it is needed to to conduct our legitimate business purposes or to comply with our legal obligations, or until you ask us to delete your data. For example, we will retain certain personal information indefinitely for the purposes of maintaining your account, unless and until you delete your account. Data that we gather for a specific and particular purpose, such as assisting law enforcement or analyzing trends, will not be kept for longer than is necessary for that particular purpose. Data that is no longer needed by us for any of the purposes listed above will be permanently deleted.
You may request that we delete your data at any time. However, note that we cannot control the retention policies of third parties. If you wish to have any third parties, including those to whom we’ve transmitted your data, delete that data, you will need to contact those third parties directly. You may request from us a list of all third parties to whom we have transmitted your data.
SECURITY OF YOUR INFORMATION
We take all reasonable steps to protect your personal data and keep your information secure. We use recognized online secure payment systems and implement generally accepted standards of security to protect against personal data loss or misuse. However, no security measure is foolproof, and no method of data transmission can be guaranteed against interception or misuse. We cannot guarantee complete security of any information you transmit to us.
We will notify you of promptly any known breach of our security systems or your data which might expose you to serious risk.
This website or mobile app is not designed for use by children under age 16, and we do not knowingly solicit personal data from anyone under age 16. If you are under age 16, do not access or use our website or related products or services. If you become aware that we have collected data of anyone under the age of 16, please contact us so that we may delete that data.
You have certain rights with respect to your personal data, as outlined below. Note that we may charge you a reasonable fee for actions that you ask us to take with respect to your data. In addition, we reserve the right to request that you provide us with evidence of your identity before we take any action with respect to the exercise of your data rights. Further, your rights may be restricted or nullified to the extent they conflict with our compelling business interests, the public interest, or the law. To exercise any of the rights outlined below, please contact us at firstname.lastname@example.org.
Update Account Information: You have the right to update, change or delete any information you have provided to us.
Confirm Personal Data and Its Use: You have the right to request that we confirm what data we hold about you, and for what purposes. You also have the right to confirmation of whether we process your data or deliver your data to third party processors, and for what purposes. We will supply you with copies of your personal data unless doing so would affect the rights and freedoms of others.
Change Consent: You have the right to change your consent to our use of your information. In such cases, we may require you to delete your account with us, and you may not have full access to our website.
Request a Copy of Data: You have the right to request a digital copy of the data that we hold about you. Your first request for a copy of your personal data will be provided free of charge; subsequent requests will incur a reasonable fee.
Transfer Your Data: You have the right to request that we gather and transfer your data to another controller, in a commonly used and machine readable format, unless doing so would cause us an undue burden.
Delete All Data: You have the right to request that we delete all data that we hold about you, and we must delete such data without undue delay. There are exceptions to this right, such as when keeping your data is required by law, is necessary to exercise the right of freedom of expression and information, is required for compliance with a legal obligation, or is necessary for the exercise or defense of legal claims. Such a request may result in a termination of your account with us and you may have limited or no use of our website.
Emails And Communications: You may opt out of receiving future email correspondence from us by checking the appropriate box when you register for the account or make a purchase. You may change your communication settings by contacting us at email@example.com.
Marketing Communications: You may opt out of receiving any third party marketing communications or having your personal information used for marketing purposes. You may do this by contacting us at firstname.lastname@example.org.
Processing: You may, in some circumstances restrict the processing of your data, such as when you contest the accuracy of your data or when you have objected to processing, pending the verification of that objection. When processing has been restricted, we will continue to store your data but will not pass it on to third party processors without your consent, or as necessary to comply with legal obligations or protect your rights or those of others or our company. In addition, you may opt out of any processing of your data altogether. Note however that doing so may result in the termination of your account and loss of access to our website.
CALIFORNIA PRIVACY RIGHTS
The State of California has established its own unique regulations that apply to California residents. If you reside in California, you have the right to obtain from us, once per year and free of charge, information regarding what information we disclose to third party marketers, and the names and addresses of each third party to whom we disclose your data. If you are a California resident and would like to make such a request, please use the contact information listed below.
If you are a California resident and under the age of 18, you have the right to request that we remove any data that you publicly post on our website. To request removal of your data, please use the contact information listed below. Note that while we will remove your data that is publicly posted on our website, we may not be able to completely remove that data from our systems.
We offer the opportunity for you to volunteer certain information to us that is used for email and marketing purposes. This information includes, but is not limited to, your name and email. You will have an opportunity to unsubscribe from any future communications via email, but we reserve the right to maintain a database of past email subscribers. We reserve the right to use this information as reasonably necessary in our business and as provided by law. Your information will be shared with reasonably necessary parties for the ordinary course of conducting our business, such as through Facebook ads or Google Pay Per Click marketing campaigns. We do not ever sell your information to third parties.
The information contained herein constitutes the entire agreement between site users and our company relating to the use of this website.
LAW AND JURISDICTION