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.
1) Scope of Policy.
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.
3) 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.
4) 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.
5) 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.
6) Information We May Collect from You.
We may collect and process the following types of information about you.
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.
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:
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.
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.
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.
Note: You may disable Cookies in your browser settings. Please keep in mind, disabling all Cookies may impair functionality.
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.
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.
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.
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.
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.
13) 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.
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.
15) Your Rights.
Typically, you have the following rights:
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.
16) 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.
Attention: Data Compliance Officer
U.S. Tel: xxx (ask for the Data Compliance Officer)