Updated November 12, 2018

We are committed to protecting and respecting your privacy. We also encourage you to review privacy choices you have in your computer’s settings. We understand that you care about the use and storage of your Personal Data. This policy explains the information we might collect, use, share, and keep about you, and may change from time to time so please check back here frequently. If you disagree with this Privacy Policy, please discontinue accessing or Using our Products and Services. Our Terms of Use and Disclaimers and Limitations on Liability are incorporated in this Privacy Policy as if fully set forth herein.

1. Scope of Policy.

This Privacy Policy applies to:

• Visitors to our Sites, including but not limited to www.LyfeSpark.com and any of our Affiliates’Sites:

• who request information by e-mail or telephone,
• who provide or post User Content,
• who apply for one of the career vacancies listed on Sites,
• who purchase or license Products and Services from us, our resellers, or our Affiliates,or
• who participate in any survey.

• End Users of our Products and Services provided by us or our Affiliates or Business Partners.
• End Users of any of our Products and Services accessible through any of our downloadable or Internet-based programs or applications.

Our Products and Services are not available in the European Union (EU) or European Economic Area (EEA). Please see our Terms, Section 2 (Definitions) for information regarding the definition of Personal Data.

1. Consent.

You are never required to provide us with the types of information covered by this Privacy Policy. By accessing or Using our Products and Services, and/or providing User Content to us, you do so voluntarily and are expressly opting-in and unambiguously consenting to the collection, use, retention, disclosure, and transfer, including cross-border transfer, of your Personal Data as explained in this Privacy Policy. In some instances, your employer may ‘opt in’ on your behalf by separate agreement.

1. No Use by Children.

Unless we have obtained parental or legal guardian consent or we are working with a school and have obtained parental or legal guardian consent through the school, we do not knowingly collect Personal Data from anyone under the age of thirteen (13) in the U.S. Our Products and Services are directed at people who are at least the age of majority where they live. If you believe your child has provided us with any Personal Data, please contact us by email at privacy@LyfeSpark.com and we will promptly delete that information.

1. Sharing Personal Data/Unrelated Third Parties.

We do not share, sell, or rent Personal Data to or with unrelated third parties without providing you a choice. Personal Data that you provide to us while Using our Products and Services may be used to contact you for promotional offers, marketing programs, or other communications from us or our Business Partners.

1. Sharing Personal Data/Business Partners.

Our Business Partners who have access to your Personal Data in connection with providing Products and Services to us or you are required to keep your information confidential and are not permitted to use this information for any other purpose than to carry out the services they are performing for us or to communicate with you regarding legitimate business purposes as long as you have the option to opt out of that communication. When we make Personal Data available to our Business Partners, we will not share with them any more Personal Data than is necessary; and we will use reasonable efforts to request that they use your information in a manner that is consistent with this Privacy Policy.

1. Information We May Collect from You.

We may collect and process the following types of information about you.

Commercial Requests.

What we Collect.

When you download marketing collateral or contact us, we collect and maintain some personal information so we can include you in our marketing database, comply with your request, and send you information on our Products and Services. Information we collect for these purposes usually includes your name and contact information. Where you contact us by phone, we may also keep a copy of that correspondence and your telephone number. How Is It Used? We may use information we collect from you to:

• provide you with the information requested,
• provide you with information that is similar to your inquiry, which may include marketing or promotional opportunities, and
• notify you about changes to our Products and Services

Why do we use it? We use information collected to take necessary steps to respond to a request and/or to provide Products and Services requested. In addition, direct marketing is necessary for the legitimate business interests we are pursuing. Who has access to it? Collected Personal Data is available to our employees with a legitimate business need, such as our marketing, order fulfillment team, and operations team. Your full prospect profile is stored with an outside third-party customer relationship management (“CRM”) company (Infusionsoft.com). We also use a third-party email marketing company (Memberium.com and Authorize.net.), which company will maintain your name and email.

Clients.

What we Collect.

By subscribing to our Products and Services, you are consenting to providing us with certain information that may be considered Personal Data, including your name, telephone number, address, credit card information, email address, IP address, geolocation, gender, and age. We also collect your selected login password. We do not

How is it Used? We use the information provided to us to:

• manage, and charge you for, your account,
• carry out our obligations arising from any contracts entered into between you and us,
• provide you with information requested, which may include marketing or promotional opportunities,
• provide you with our Products and Services, and
• notify you about changes to our Products and Services.

Why do we use it? Processing is necessary to perform a contract with you, perform legitimate business purposes, provide you with Products and Services requested, or to take steps at your request prior to entering into a contract. Who has access to it? Information collected is available to our employees with a legitimate business need such as our marketing, order fulfillment team, operations team, Affiliates, and our Business Partners who process credit card payments. Your profile is stored with an outside third-party customer relationship management (“CRM”) company (Infusionsoft.com). We also use a third-party email marketing company (Memberium.com and Authorize.net.), which company will maintain your name and email. You may view the privacy policies of these Business Partners at https://www.infusionsoft.com/legal/privacy-policy, https://memberium.com (and click on Privacy Policy at the bottom of the page), and https://www.authorize.net/about-us/privacy/. We are not responsible for the policies of third parties whatsoever. We only collect information from you that may be considered Personal Data that is required for our legitimate business purposes. We do not request or require you to provide any special categories of Personal Data including, for example, genetic data, biometric data, or information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, or sexual orientation. You may, however, upload User Content that includes special categories of Personal Data. If so, this data will be transferred to and maintained on our servers. If you delete your User account, this information will be deleted from your page, but we will retain a copy of your User Content (in the form of your vision board(s)) in our library for use of our other subscribers). If we become aware of any special categories of Personal Data having been submitted to us, other than in your posted User Content, we will, where reasonably practicable, endeavor to delete it.

1. Cookies.

A “Cookie” is a small amount of data generated by a website and saved by your web browser. When you access or Use our Products and Services, we use the below types of Cookies. Accessing our Sites or Using our Products and Services constitutes consent to our use of the Cookies detailed below. Please note that if you set your Internet browser to disable all Cookies, including Strictly Necessary Cookies, our Products and Services will not function. For more information on how Cookies function and disabling Cookies, consult your browser’s “help” button or your browser’s “security “settings.

• Strictly Necessary Cookies. These Cookies enable you to browse the Sites and UseProduct and Service features. Without these Cookies, Products and Services such as subscriptions, e-billing, and shopping carts cannot be provided.

• Session Cookies. Our Sites use session Cookies that your computer stores only for that browsing session. Once you close your browser, the Cookie is deleted. These Cookies allow EndUsers to navigate around our Sites using your login details without having to login again on every page.

• Performance Cookies. These Cookies collect information about how visitors utilize our Sites, allowing us to improve our Products and Services. These Cookies also let Business Partners know if you came to our Sites from a BusinessPartner’s site and if your visit resulted in a purchase. Only your IP address or domain name and Uniform Resource Identifier (URI) or web address are collected.

• Functionality Cookies. These Cookies allow our Sites, or our Affiliates’ sites, to remember choices you make while browsing a Site. We may store geographic location to ensure our Sites are optimized for your area or we may store text, font, or other customizable elements. These Cookies will not track your browsing activity on other websites.

• Targeting or Advertising Cookies. These Cookies are used to deliver advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They may be placed by our Affiliates or Business Partners or by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.

• Web Beacons and Parameter Tracking. These Cookies count visitors or End Users who have visited our Sites after clicking through from one of our advertisements on another website or in e-mails and to collect details of any Products and Services purchased.

• Google Analytics Tracking Cookies. These Cookies allow us to understand more about visitors to our Sites, such as the number of visitors, details of the devices used to access our Products and Services, which pages are accessed, and the various time details per visit.

Note: You may disable Cookies in your browser settings. Please keep in mind, disabling all Cookies may impair functionality. For more detailed information on the Cookies we use and the purposes for which we use them, please see our Cookie Policy set out at http://www.LyfeSpark.com/CookiePolicy.

1. Security.

Where we store Personal Data.

We use servers in the United States to process and store Personal Data collected, including servers provided by our third-party provider https://www.Linode.com. While no server can be completely secure, we make reasonable efforts to ensure that these servers are kept in a secure, locked environment with restricted access and we have on our own, and in conjunction with the third parties who operate the servers, established physical, electronic, and procedural safeguards to protect your information. Personal Data stored by us may be accessed and processed by staff operating outside where you reside, who work either for us (including our Affiliates) or for one of our Business Partners. This staff may be engaged in fulfilling your order or request, processing a payment, and/or providing support services to us. We require these Business Partners to agree to treat your Personal Data securely and in accordance with this Privacy Policy and applicable Law. We have implemented a variety of technical and organizational measures to protect Personal Data from loss, misuse, unlawful processing, unauthorized access, disclosure, copying, alteration, and destruction. These include limiting access to the databases to a limited number of authorized staff, who are required to enter into non-disclosure agreements before access is afforded to them and who can only access the database for legitimate pre-authorized purposes. Further, access to the databases is password protected. We also have in place audit logs, intrusion detection software, anti-virus or malware protection, and system integrity tools to further protect data stored on these databases.

1. Passwords.

Where we have provided you (or where you have chosen) a user name and/or password that enables you to access certain portions of our Products and Services, you are responsible for keeping this password confidential. You are responsible for protecting your account by not sharing your user name and password with anyone.

10. Hackers.

While we make reasonable and industry-standard efforts to ensure the integrity and security of our network and systems using the standard measures in place through our Sites’ host(s), we cannot guarantee that such security measures will prevent third-party “hackers” from illegally obtaining this information. We are not responsible for circumvention of any privacy settings or security measures contained in our Products and Services, including the illegal acts of third parties (such as criminal hacking). We disclaim any and all liability for disclosure of any information obtained due to errors in transmission or the unauthorized acts of third parties as more specifically detailed in our Disclaimers. ANY TRANSMISSION IS AT YOUR OWN RISK.

11. Third-Party Websites.

Our Products and Services may, from time to time, contain links to and from third-party websites. We only link to the home page of third-party content unless we have a separate agreement with a third party. If you follow a link to any of these websites, please note that these websites and any products or services that may be accessible through them have their own privacy policies; and we do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or their products or services. We urge you to exercise care when providing information to anyone and to check the policies and terms of all third-party websites before you submit any Personal Data.

12. Advertising.

We may use third-party advertising companies to serve ads when you access or Use our Products and Services. Such third-party companies may use information (not including your name, address, or e-mail address) about your visits to this and other websites to provide advertisements on sites, goods, and products or services that may be of interest to you. If you would like more information about this practice, and to know your choices about not having this information used by these companies, please review your rights at the Network Advertising Initiative. You may ask websites not to track you in your browser’s preferences.

1. Social Media.

When you use features such as social networking, chat rooms, or forums, you should take precautions not to submit any Personal Data that you do not want to be seen, collected, or used by others. Our Products and Services include features from social media websites. These features may collect your IP address, which page you are visiting on our Site, and may set a Cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy, terms, and other policies of the companies providing those features.

1. Retention.

The amount of time we hold your Personal Data will vary but will not be kept for longer than is necessary for the purposes for which it is being processed. We will retain your Personal Data in accordance with the following criteria: Commercial Requests. We will retain your Personal Data solely for the legitimate business purpose of responding to your request or inquiry and to communicate with you regarding our other Products and Services. You may opt out of such communications at any time and you will be provided with that opportunity within each communication. Client Information. If you are a client, we will retain your Personal Data indefinitely while you are Using or accessing our Products and Services. When you stop Using our Products and Services, we will retain your Personal Data for a reasonable period of time in order to allow you to download any User Content, if any, stored therein. Thereafter, your Personal Data will be deleted, restricted, pseudonymized, or anonymized (so that it cannot be connected with a particular individual, company, or IP address). We will retain non-personally identifiable Images you upload to your vision board(s) in our library for use by us and other subscribers.

1. Your Rights.

You have certain rights in relation to the Personal Data we process. These rights to access, correct, amend, or delete Personal Data vary by location and only the rights available to you in your physical location will be enforceable by you under this Privacy Policy. Typically, you have the following rights:

• The right to access your Personal Data unless access is subject to a legal exception.
• The right to have your Personal Data corrected if it is inaccurate or incomplete.
• The right to have your Personal Datanot processed.
• The right to have your Personal Data erased if it is no longer necessary or required in relation to the purposes and there are no other overriding legitimate grounds for us to continue processing it.
• The right to opt out if your Personal Data is to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or you subsequently authorized.
• The right to complain to a supervisory authority if you think your rights have been infringed.
• You may also have the right to request that a business disclose the categories or details of Personal Data collected.

To exercise your rights, you may make an inquiry by sending an email request directly to our Data Compliance Officer at privacy@LyfeSpark.com. We will respond to your request in accordance with the Laws that apply to you. When you make your request, we will maintain your request and related Personal Data as we maintain other Personal Data for Commercial Requests in order to respond, after which time we will delete the Personal Data provided in the request. Access requests are free; however, we reserve the right to charge a reasonable fee to comply with your request when your request is unfounded or excessive.

1. Transfer of Personal Data.

Where we transfer Personal Data relating to third parties, we will request they maintain the privacy of such Personal Data and only use it in compliance with applicable Laws. We will provide reasonable and industry standard technical and organizational measures to protect Personal Data from accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access.

17. California Users.

Under California’s “Shine the Light” law, and once per year, California, U.S. residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from the seller the customer information shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information during the immediately prior calendar year. If you believe this law applies to you, please send an e-mail message to Data Compliance Officer at privacy@LyfeSpark.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 at your e-mail address in response only if the law applies to you. We will maintain your request and the Personal Data you provided in that request for ninety (90) days to ensure you do not have any follow-up questions. After that time, the Personal Data associated with your request will be destroyed. 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.

1. Complaints.

If you have a complaint regarding this Privacy Policy or how your Personal Data is being maintained, used, or processed, you should first contact our Data Compliance Officer, whose contact details appear below: Attention: Data Compliance Officer Privacy@LyfeSpark.com

1. Contact.

Questions, comments, notices, and requests regarding this Privacy Policy are welcomed and should be emailed to our Data Compliance Officer at privacy@LyfeSpark.com. Please make sure that you identify the Site and/or Products or Services through which you submitted Personal Data to enable us to identify your records. We will respond to your communications within thirty (30) days unless your request involves information that requires significant and/or unusual research.

1. Changes to Privacy Policy.

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or provided when you next visit our Sites or when you next access our Products and Services. The new policy may be displayed on-screen and you may be required to read and accept this policy to continue your access and Use of our Products and Services.