Last Modified: June 24, 2019
- On or through this Website.
- In email, text, and other electronic messages between you and this Website.
It does not apply to information collected by:
- The Company offline, or through any other means not listed above, including on any other application or website operated by the Company, its affiliates, or subsidiaries; or
- Any third party (including our affiliates and subsidiaries), including through any application advertising, or other content that may link to or be accessible from, or on, the Website. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
The Company’s Privacy Assurance
- We do not sell your Personal Information to any nonaffiliated third parties.
- We do not share your Personal Information with nonaffiliated third parties that would use it to contact you about their own products and services, unless you have allowed us to do so and as permitted pursuant to a joint marketing agreement.
- We require our employees to protect your Personal Information and keep it confidential.
- We require persons or organizations that represent or assist us in serving you to keep your information confidential.
CHILDREN UNDER THE AGE OF 13:
Our Website is not intended for children under 13 years of age. No one under the age of 13 may provide any Personal Information to, or on, the Website. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this Website, or on or through any of its features/functionality, make any purchases through the Website, use any of the interactive or public comment features that may be available on this Website, or provide any information about yourself to us, including your name, address, email address or any other personal information.
If we learn that we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
INFORMATION WE COLLECT:
We collect several types of information from and about users of our Website, including log data, device data, and Personal Information.
When you visit our Website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.
We may also automatically collect data about the device you are using to access our Website. This data may include the device type, operating system, unique device identifiers, device settings, and location data. What we collect depends on the individual settings of your device and software.
We may collect information from you while you use this Website, including:
- By which you may be personally identified, such as your first name, last name, email address, credit card number, and other identifying information that you choose to share with us by which you may be contacted online or offline ("Personal Information"); and/or
- That is about you but individually does not identify you, such as your annual revenue, gender, certain demographic information. This information is not considered Personal Information, as it is anonymized statistical data.
LEGAL BASES FOR PROCESSING:
We will process your Personal Information lawfully, fairly, and in a transparent manner. We collect and process information about you only where we have legal bases for doing so. These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:
- You give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter);
- It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service, such as a course, you request from us);
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as to present the Website to you, for research and development, to market and promote our services, and to protect our legal rights and interests; or
- We need to process your data to comply with a legal obligation.
RESTRICTING YOUR PERSONAL INFORMATION:
You may choose to restrict the collection or use of your Personal Information.
If you have previously agreed to us using your Personal Information for direct marketing purposes, you may change your mind at any time by contacting us by email at email@example.com (but this will not affect any processing that has already taken place). If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our Website or products and services.
HOW WE COLLECT INFORMATION:
Information We Collect Automatically
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, as described above. The technologies we use for this automatic data collection may include cookies, flash cookies, or web beacons. For more information on these technologies, see our DATA COLLECTION POLICY below. The information we collect automatically is statistical data and does not include Personal Information, but we may maintain it for any of the reasons listed in HOW WE USE YOUR INFORMATION.
Information You Provide Directly to Us
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering for our newsletter or to use our Website or while participating in a course. We may also ask you for information when you report a problem with our Website;
- Records and copies of your correspondence (including email addresses), if you contact us;
- Details of transactions you carry out through our Website; and/or
- Your search queries on the Website.
Information Provided to Us by Third Parties
CHOICE & CONSENT:
DATA COLLECTION POLICY:
The technologies we use for automatic data collection on this Website may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies; and/or
- Web Beacons. Pages of the Website, and our emails, may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages, or opened an email, and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
DO NOT TRACK:
“Do Not Track” is a preference you can set in your browser to let websites you visit know that you do not want them collecting certain information about you. We do not currently respond to, or honor, Do Not Track signals or requests from your browser.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
We may collect information about your actual location when you use our Website. Location information may help us tailor our Services for you, for example, by notifying you of local events or classes in your area.
We use various technologies to obtain your location. Your location can be determined with varying degrees of accuracy by:
- IP address
- Sensor data from your device
- Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices
You can avoid tracking when interacting with the Website by denying a request to share location information when prompted by your browser. Your device and/or browser may also provide alternative methods to turn off location sharing.
PURPOSE OF PROCESSING & HOW WE USE YOUR INFORMATION:
We only collect information for reasons that a reasonable person would consider appropriate in the circumstances. We may collect your information for a number of reasons, specifically:
- To enable you to access and use our Website and courses;
- To contact and communicate with you;
- To prevent fraud;
- For internal record keeping and administrative purposes;
- For analytics, market research, and business development, including to operate and improve our Website;
- To offer additional benefits to you, including but not limited to sending promotional information about our products/services and/or facilitating challenges and/or giveaways;
- To fulfill any other purpose for which you provide your information and consent; and/or
- To comply with our legal obligations and resolve any disputes that we may have.
DISCLOSURE OF YOUR INFORMATION, GENERALLY:
- To our subsidiaries and affiliates;
- To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
- To fulfill the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information; or
- With your consent.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES:
We may disclose your Personal Information to third party service providers for the purpose of enabling them to help us provide our services, including but not limited to:
- Information Technology (“IT”) service providers;
- Data storage, hosting, and server providers;
- Error loggers;
- Maintenance or problem-solving providers;
- Marketing or advertising providers;
- Professional advisors and payment systems operators; and/or
- Sponsors or promoters of any challenge or promotion we run.
We may also disclose your Personal Information to third parties for the purpose of establishing, exercising, or defending our legal rights, including but not limited to:
- Debt collectors;
- Our legal counsel and/or prospective legal counsel; and/or
- Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law.
We may disclose aggregated, anonymized, statistical data and/or non-identifying information about our users without restriction.
As noted above, we do not sell your Personal Information to any nonaffiliated third parties, and we do not share your Personal Information with nonaffiliated third parties that would use it to contact you about their own products and services, unless you have allowed us to do so and as permitted pursuant to a joint marketing agreement.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION:
The Personal Information we collect is stored and processed where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your Personal Information, you consent to the disclosure to any overseas third parties HLT utilizes to provide the services through the Website.
We will ensure that any transfer of Personal Information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Where we transfer Personal Information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in your jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in your jurisdiction and this might mean that you will not be able to seek redress under your jurisdiction’s privacy laws.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION:
We strive to provide you with choices regarding the Personal Information you provide to us. The following mechanisms should help to provide you with control over your information:
- Promotional Offers and Marketing Emails from the Company. If you do not wish to have your email address/contact information used by the Company to promote our products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org. If we have sent you a promotional email, you may use the unsubscribe option in the footer of the email. This opt out does not apply to information provided to the Company as a result of a product or service purchase, or other transactions.
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
ACCESSING AND CORRECTING YOUR INFORMATION:
If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can review and change your Personal Information by sending us an email at email@example.com to request access to, correct, or delete any Personal Information that you have provided to us. We may not be able to delete some of your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or regulatory requirement, result in fraud, or cause the information to be incorrect.
ACCESS & DATA PORTABILITY:
You may request a copy of the Personal Information we hold about you at firstname.lastname@example.org. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the Personal Information we hold about you at any time. However, you understand that any erasure of Personal Information may affect our ability to provide our services, content, or the Website to you. You may also request that we transfer this Personal Information to another third party.
YOUR CALIFORNIA PRIVACY RIGHTS:
If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your Personal Information with third parties for their own direct marketing uses. California’s “Shine the Light” Act provides that you have the right to submit a request to us at our email address in order to receive information on the categories of customer information that we shared and the names and addresses of those businesses with which we shared customer information for the past calendar year. To obtain this information, please send an email message to email@example.com with "Request for California Privacy Information" in the subject line and in the body of your message. We will provide the requested information to you in your email address in response.
Please be aware that not all information sharing is covered by the Shine the Light requirements, and only information on covered sharing will be included in our response.
We won’t keep Personal Information for longer than is necessary to present our Website to you or to provide our services to you. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. If necessary, we may retain your Personal Information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us through the Website is secured by TLS technology, and is stored on our secure, password protected servers behind firewalls. We have implemented a restricted employee access for all of our servers containing personally identifiable information.
Any payment transactions will be encrypted using SSL technology. We use Stripe and Paypal (PCI-DSS compliant) as our payment processors.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
We will comply with any laws applicable to us in respect of any data breach.
COMPLAINTS & CONTACT INFORMATION:
If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
DATA CONTROLLER & DATA PROTECTION OFFICER:
Our Data Controller is Hello Lauren Turton and may be contacted at firstname.lastname@example.org.
Our Data Processor is CNG Digital Marketing and may be contacted at 3950 Sorrento Valley Blvd Suite 400, San Diego, CA 92121.