2. The Information We Collect
Our Platform gives us the opportunity to communicate with people interested in Focus Funnels’s blog, podcasts, online training programs, coaching, consulting, and their other activities and interests. The Platform also provides you with opportunities to participate in exchanges on these topics, and to receive additional information on all of the above. To provide these Services, and to otherwise conduct our business via the Platform, we rely on information provided by and collected from our users. This information consists of the following:
2.1 Personal Information. We collect certain information that identifies you as an individual (collectively, “Personal Information”). The Personal Information we collect may include the following:
- Your name;
- Your email address;
- Social media handle (e.g., if you engage with us on social media);
- Your billing and/or shipping address; and
- Your payment information.
2.2 Automatically Collected Technical and Device-Related Information. We also collect technical and device-related information that identifies or may reasonably be used to identify a particular user device (collectively, “Automatically Collected Information”). Automatically Collected Information is typically collected automatically by technical means, and for purposes of our Platform consists of the following:
- Device identifiers, such as cookies;
- Device information, such as hardware and software settings;
- IP addresses and log information, such as your device’s name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
- Tracking information that we collect, or that third parties collect.
2.3 Anonymous Information. Our Platform also collects, processes, and/or uses information that does not identify you or your devices, including Personal Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or perturb the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information”). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information about how the Website is used.
If we combine or associate Automatically Collected Information or Anonymous Information with Personal Information, we treat the resulting combination as Personal Information.
3. How We Collect This Information
We collect the above information through the following means and technologies:
3.1 Registration. In order to provide you with the Services, we need to collect Personal Information consisting of your name and email address. Accordingly, when you register to receive the Services, you provide this Personal Information.
3.2 Payments. When you order certain Products or Services through our Website, we will require you to submit your payments using the payment method we have implemented on our Website. The payment information we will collect during this process will include your credit or debit card number or your bank account number, the expiration date of your credit or debit card, purchase amount, date of purchase, and payment method. We may also collect certain Personal Information from you, such as your name, billing address, and, if applicable, shipping address. Please note that different payment methods may require us to collect different categories of information. Depending on the payment method we have chosen to implement on our Website, we may collect your transaction information (i) directly from you for transfer to our payment processor, or (ii) through the third party payment processor(s) that we have authorized to collect such information from you on our behalf. For more information on our privacy practices with respect to our service providers, please refer to Section 5.2 (Our Service Providers).
3.3 User-Generated Content. We give you the ability through the Platform to engage with Focus Funnels and others in public exchanges, and these include opportunities for you to provide comments, reviews, recommendations, and other input via the Platform (collectively, “User-Generated Content” or “UGC”). Please understand that, if you include Personal Information in User-Generated Content, others will be able to read, collect, re-publish, and otherwise freely use the information. We are not responsible for Personal Information you decide to include in UGC, and we will not take down, remove, or edit User-Generated Content, except as required by Applicable Law. If you include in your User-Generated Content any Personal Information relating to others, you represent that you have full permission and authority to do so.
3.4 Contests, Special Offers, and Surveys. On occasion, we will provide you with the opportunity to participate in contests, receive a special offer, or provide us with feedback via a survey. To make these Services available to you, we will use the email address and name you provided us when you registered.
3.5 Beacons and Tags. The Platform may use certain data collection technologies that rely on (i) beacons; (ii) pixel tags and object hyperlinking tags, and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what parts of our Platform have been visited or to measure the effectiveness of searches that users perform on our Platform. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information, Automatically Collected Information and, in certain instances, Personal Information.
3.6 Device Identifiers; Logs; IP Addresses. To determine whether your device is supported by our Platform, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Platform, as well as the presence of any software that our Platform may require to operate with your device, or other third party software or mobile apps on your device. We automatically receive and record this information in log files, and this is generally Automatically Collected Information.
3.7 Cookies. A cookie is a small amount of data which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies; however, you may need to enable cookies on your web browser if you wish to access certain personalized features of our Services. Cookies are a form of Automatically Collected Information. Please visit http://www.allaboutcookies.org/ and https://cookies.insites.com/disable-cookies/ for more information on how you can disable some or all cookies.
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.
Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.
3.8 Click-Throughs. We may send email messages or display links that use a “click-through URL” linked to our Platform or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information and Automatically Collected Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.
3.9 Advertising Technology. The Services may include use of banner ads and other vehicles for presenting advertising content, and for serving and/or targeting ads, promotions, and other marketing messages, including through use of user profiles, online behavioral advertising methods, and related technologies. These ads may be provided, in some cases, by a third party service, as discussed in Section 5 (How We Share This Information). An advertiser, as described in Section 5.3 (Third Party Advertising), may place or utilize its own cookie or other identifier on your device, and may use Anonymous Information about your visit to our Platform, such as the number of times you have viewed the ad, as well as applicable Automatically Collected Information.
4. How We Use This Information
We use the information we collect or process, including Anonymous Information, Automatically Collected Information, and Personal Information, as permitted under Applicable Law, including where the use is based on (a) the consent you provide to us; (b) performance of our agreement to provide you with the Services; (c) compliance with our legal obligations; and/or (d) our Legitimate Interests, as well as a third party’s Legitimate Interests.
5. How We Share This Information
We value your privacy, and we share the information we collect only in the manner set out below.
5.2 Our Service Providers. We engage third parties to perform functions on our behalf, and these may include maintaining the Platform, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personal Information, Automatically Collected Information, and Anonymous Information as applicable. The following are examples:
- We use service providers (a) to fulfill your orders (where applicable), (b) to provide customer service (where applicable), (c) to process and distribute email, including Focus Funnels’s email newsletter, (d) to process and display User-Generated Content ; and (e) to manage promotions, special offers, and similar activities. These service providers generally require access to your Personal Information in order to perform these services.
- We use analytics service providers to assist us in understanding and using Automatically Collected Information. A service we use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners, and opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout.
- We may use service providers to anonymize and aggregate Personal Information in order to generate Anonymous Information.
- We may engage service providers to analyze the interests and attributes of our users and, using techniques based on Anonymous Information and Automatically Collected Information, identify others who might share those interests and attributes. We then use this information to reach out to relevant market segments to provide them information concerning the Platform.
5.3 Third Party Advertising. We may share Automatically Collected Information and Anonymous Information with third parties for their marketing purposes and activities. These marketing activities may take place on our Platform or via online services, mobile apps, traditional channels, and other methods independent of our Platform. These activities may involve a third party placing its cookies, beacons, and/or tags on our Platform, in the manner specified in Section 3.5 (Beacons and Tags) and 3.7 (Cookies). We do not monetize your Personal Information for third parties’ advertising or marketing purposes.
- We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- We use Facebook, LinkedIn, Pinterest, & Google.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
- FACEBOOK – https://www.facebook.com/settings/?tab=ads
- GOOGLE – https://www.google.com/settings/ads/anonymous
- BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]
- PINTEREST – https://help.pinterest.com/en/article/personalization-and-data
- LINKEDIN – https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
5.4 Questions of Harm; Legal Process. We may disclose your Personal Information and Automatically Collected Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary:
- To comply with legal process;
- To protect and defend our rights and property, including the Platform and associated content;
- To protect against fraud, misuse or unauthorized use of our Services;
- To protect the personal safety or property of Platform users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections);
- To cooperate with public and government authorities including, where required, authorities outside your jurisdiction.
6. Our Retention Of Data
We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with Applicable Law. We use the following criteria to set our retention periods: (a) the duration of our relationship with you; (b) the existence of a legal obligation as to the retention period; and (c) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
7. Accessing And Updating Your Information
If you would like to review, correct, or update the Personal Information that you have provided to us, or if you would like to request an electronic copy of your Personal Information, you may make such requests by emailing us at email@example.com. If you email us, please provide your full name, email address you have used to access the Services, and specify the type of request you are making. We will verify your identity using the email address we have in our records.
8. Your Right To Opt-Out, Object To Processing, And Delete Information
8.1 Unsubscribing to Email. If you no longer wish to receive email messages from us, you can opt out of this Service by either (1) following the “unsubscribe” instructions located near the bottom of each email message, or (2) emailing us at firstname.lastname@example.org.
8.2 Deleting Your Information. You may request that we delete your Personal Information, and we will do so within the time frames (if any) set out in Applicable Law. Please note that deletion requests are subject to certain limitations, for example, we may retain information as permitted by Applicable Law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate user requests.
9. Advisory Regarding Participation By Children And Teens
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/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.
10. Relationship To Terms Of Service; Incorporation Of Terms Of Service
11. Notice Of Privacy Rights To California Residents
California residents also have the right under the CCPA to request access to their specific information that a business collects, uses, discloses or sells (as applicable), and the right to request deletion of their information. California residents may exercise their rights as provided above in Section 7 (Accessing and Updating Your Information) and Section 8.2 (Deleting Your Information). California residents may authorize another person (your “agent”) to submit an access or deletion request on your behalf. In that event, we will verify your agent is properly authorized to act on your behalf by contacting you directly. We will not discriminate against you in price or service for exercising your CCPA rights.
We do not monetize users’ Personal Information, and under California law, we do not “sell” Personal Information to third parties. Nor do we disclose the categories of information listed in California’s “Shine the Light” law to third parties for their direct advertising purposes.
If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.
Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.
13. Notice Of International Data Transfers
We are based in the United States. If you live or reside outside the United States, be aware that your Personal Information will be transferred and processed in the United States. By using the Services or Platform, or providing us with your information, you fully understand and consent to this transfer and processing of your Personal Information in the United States—a jurisdiction may have data protection rules that are different from those in your country.
14. Third Party Sites
The Platform may link to third party websites, social media platforms or other online services, and such links are provided for your convenience only. We have no control over such third parties, and if you decide to access any of the third party links from the Website, you do so subject to the terms and conditions of use and privacy policies for such third parties.
We want your feedback. If you have suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 19 (Contact Us).
If you are protected by the GDPR with respect to our use of your information, you may lodge a complaint with a data protection authority for your country or region. A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
17 . Contact Us
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at email@example.com or by mail using the details provided below:
Focus Funnels LLC, 188 Front Street, Suite 116, Franklin TN 37064, United States