Effective Date: July 1, 2022
We at ThroughConversation Personal Development North America Limited LLC (“Company”, “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you – our visitors, users and customers.
By using the Platforms, you agree to the terms of this Policy, our Terms of Service (located here https://throughconversation.com/terms-of-service/) or any other agreement that governs your use of our Platforms (collectively, “Agreements”). You should not use our Platforms if you do not agree with the terms and conditions contained in these Agreements.
1. WHAT INFORMATION WE COLLECT
a. Information You Provide Us
We collect information you provide directly to us. For example, we collect information when you create an online account, sign up to receive our emails, communicate with us on the Platforms or via third-party social media sites, or order our products or services. The type of information we may collect include your:
- email address
- zip code
- residential address
- work address
- phone number
- products purchased
- purchase date
- demographic information
- any other information you choose to provide
b. Automatically Collected Information through Tracking Technologies
- type of browser you use
- access times
- pages viewed
- time spent on pages
- links clicked
- your IP address
- the referring link through which you accessed the Site
- conversion information
2. WHAT WE USE YOUR INFORMATION FOR
We use collected information in a variety of ways, including to:
- provide the products and services you request;
- process transactions and send you related information (i.e., confirmations and receipts);
- respond to your comments, questions and requests and provide customer service;
- communicate with you about products, services, offers, promotions, and provide news and information we think will - be of interest to you;
- send you technical notices, updates, security alerts, and support and administrative messages;
- better tailor our Platforms to your interests and needs;
- carry out profiling activities in order to learn more about you; and
-offer you tailored advertising based on your behavior on our Platforms.
3. WHO WE SHARE YOUR INFORMATION WITH
a. Publicly Shared Information
Any information that you voluntarily choose to share in a public area of our Platforms (e.g., by posting a comment to a blog post or leaving a review) will be available to anyone who has access to that content.
b. To Company Employees and Contractors
We may share your personal information within the Company to our employees and contractors in order to deliver our services and products to you.
c. Third-Party Service Providers
We use third-party service providers to collect and process personal information from or about you on our behalf. Examples include data analysis, marketing and advertising services, email and hosting services, customer services and support, hosting customer accounts, processing payments, and collecting customer research. They have access to the personal information needed to perform their functions.
d. Online Advertising Services
We use third-party advertising services, like Google Ads, Facebook Ads, Instagram Ads, Youtube Ads, display banner ads, or print ads, to deliver advertising about our products and services on our Platforms, as well as other websites and applications you use. The ads may be based on information we have collected (as outlined above) and information these advertising providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.
e. Analytic Services
We use third-party browser and mobile analytics services, like Google Analytics, on the Platforms. These services use tools to help us analyze your use of the Platforms, including information like the third-party website you arrive from, how often you visit, events within the Platforms, usage and performance data, and purchasing behavior. We use this data to improve the Platforms and provide information, products and services that may be of interest to you.
f. Law Enforcement, Legal Process and Compliance
We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
g. Change of Ownership
We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the information we share.
4. KEEPING YOUR INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
5. YOUR RIGHTS
Under the General Data Protection Regulation, you may have a number of important rights free of charge. Please note that for each of the rights below we may have valid legal reasons to refuse your request. In such instances, we will let you know if that is the case. In summary, your rights include:
- Fair processing of information and transparency over how we use your use personal information;
- Access to your personal information and to certain other supplementary information that this Policy is already designed to address;
- Require us to correct any mistakes in your information which we hold;
- Require the erasure of personal information concerning you in certain situations;
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- Object at any time to processing of personal information concerning you for direct marketing;
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- Object in certain other situations to our continued processing of your personal information;
- Otherwise restrict our processing of your personal information in certain circumstances.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- Email, call, or write to us (see “How to Contact Us” below);
- Provide us enough information to identify you (e.g., account number, user name, registration details);
- Provide us proof of your identity and address; and
- Provide us sufficient information to which your request relates (e.g., any account or reference numbers).
- Email Communications: If you would like to unsubscribe from any email marketing communications we send you, you can click on the unsubscribe link at the bottom of the message.
Cookies and “Do Not Track” Signals: Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies, but note that doing so does not necessarily affect third party flash cookies used in connection with the Platforms. Further information about deleting and blocking cookies can be found at http://www.allaboutcookies.org.
Many web browsers support Do Not Track technology. To learn more about Do Not Track, visit: http://www.allaboutdnt.org/
The Company currently does have the ability to recognize Do Not Track Signals. If you enable Do Not Track, the Company will not use information about your web viewing activities on the Site.
Information from Third Parties: To manage the information we receive about you from a social media site or other third parties, you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this Policy and the information the third-party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third-party site will not apply to our use of the information we have collected directly through our Platforms.
6. THIRD-PARTY SITES
The Platforms may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Platforms. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links or access are provided through the Platforms. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
7. DATA RETENTION
We will retain your name, address, and email address for 5 years.
If you wish to have your information deleted, please contact us (see “How to Contact Us” below).
8. OUR POLICY CONCERNING MINORS
Minors should not use the Platforms. If we learn that we’ve collected personal data from a minor, we will take reasonable steps to delete it. Parents who believe that Company may have collected personal information from a minor can submit a request that it be removed by contacting us (see “How to Contact Us” below).
9. NOTICE TO CALIFORNIA RESIDENTS
If you are a California resident, you have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, please contact us (see “How to Contact Us” below) with the phrase “California Shine the Light” and include your mailing address, state of residence, and email address.
10. CHANGES AND UPDATES TO THIS POLICY
We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy, and in some cases, we may provide you with additional notice (such as sending you an email notification). We encourage you to review the Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
11. HOW TO CONTACT US
ThroughConversation Personal Development North America Limited LLC
7135 E Camelback Rd., Suite 230
Scottsdale AZ 85251