Last updated: June 10, 2021
Unless we state otherwise, this Policy applies when you visit or use the Company websites – www.annettestepanian.com - our social media channels and related platforms (“Platforms”).
By using the Platforms, you agree to the terms of this Policy, our 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.
WHAT INFORMATION WE COLLECT
a. Information You Provide Us
Here are some examples of data we collect from information you provide us:
- Payment Data: If you purchase a Company service, we collect data regarding which services you’ve purchased and how much you’ve paid for those services. We collect certain data about your purchase as necessary to process your request. You must provide certain payment and billing data directly to our third-party payment processing partners, including your name, credit card number, security code, expiration date, billing address, and zip code. For your security, the Company does not have access to or store sensitive cardholder data, such as full credit card numbers or card authentication data.
- Online Webinars: In order to enroll in one of our online webinars, you must provide certain information like your name and email address so that we can communicate information about attending the online webinar. We collect data regarding which online webinar(s) you enroll in, whether you attend the webinar and if so, for how long, whether you purchased a product during an online webinar, as well as any feedback in the form of responses to surveys and/or chat features that may be enabled for an online webinar. Such online webinars are hosted via third-party platforms, therefore, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of that third party.
- Shared Public Content: Our Platforms permit you to publicly interact with us and other users, share content, post comments, and ask or answer questions. Such shared content may be publicly viewable by others depending on where it is posted. If such information is shared on a third-party platform, such as a social media site, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of that third party.
- Giveaways, Promotions, and Surveys: We may invite you to complete a survey, provide feedback, or participate in a promotion (like a giveaway), either through our Platforms or a third-party platform. If you participate, we will collect and store the data you provide us as part of your participation, such as your name and email address and any other requested feedback. If you submit this information via a third-party platform, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
- Electronic Communications from Company: If you elect to receive email notifications from us, we collect your name and email address so that we can send you email communications about the requested information, products, and services.
- Customer Support: If you contact us (via email, phone, text, messaging platform, or through our social media channels), we may collect and store your name, email address, the content of your message, information about your business and any other data you provide
b. Automatically Collected Information through Tracking Technologies
When you visit or access the Platforms, including our email communications, we use tracking technologies like cookies, pixels, web beacons, tags, and other tracking technologies to collect information about your engagement, as well as your browsing and purchasing behavior. These tracking technologies include:
- Clickstream Data: Through web site access logs, we do collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our Platforms. This information is used for internal purposes for research and development, user analysis and business decision making, all of which provides better services to our users. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties for data processing.
- Cookies: A cookie is a small amount of data that is sent to a website users browser from a Web server and is stored on the computer's hard drive. We use non-identifying cookies to provide easier site navigation. Our Platforms can still be used if your browser is set to reject cookies. Our cookies do not generate personal data, do not read personal data from your machine and are never tied to anything that could be used to identify you. Information gathered through cookies may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
- Web Beacon Technologies. We may also use Web beacon or other technologies to better tailor our Platforms to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Platforms, a non-identifiable notice of that visit is generated which may be processed by Company or its data processors. Web beacons usually work in conjunction with cookies. If you do not want cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
We use these tracking technologies to deliver, measure, and improve our Platforms – whether accessed through a browser or a mobile device - in various ways. In particular, these technologies help:
- make our Platforms easier to use;
- better tailor our Platforms to your interests and needs;
- carry out profiling activities in order to learn more about you;
- offer you tailored advertising based on your behavior on our Platforms;
- provide better customer service, and
- compile anonymous, aggregated information that allow us to better understand our customers and visitors.
- You can opt out of Google Analytics. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page:https://tools.google.com/dlpage/gaoptout.
- To learn how to manage privacy and storage settings for Flash cookies, visithttp://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
- Further information about deleting and blocking cookies can be found athttp://www.allaboutcookies.org.
- European Interactive Digital Advertising Alliance:http://www.youronlinechoices.eu/
- Internet Advertising Bureau (US):https://www.iab.com/
- WHAT WE USE YOUR INFORMATION FOR
We use collected information in a variety of ways, including to:
- process and fulfill purchases services and keep you informed about the status of the same;
- communicate about and administer our products, services, events, online webinars, podcasts, programs and promotions (such as by sending transactional emails about your purchases and/or User Account, promotional materials, newsletters and other marketing communications);
- conduct and facilitate surveys, contests, promotions, and giveaways;
- communicate with you;
- respond to your inquiries, comments, and applications;
- conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
- operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products and services; managing our communications and customer relationships; and performing accounting and billing activities).
The legal basis for processing your personal information as described above will typically be one of the following:
- Your consent;
- Performance of a contract with you or a relevant party;
- Our legitimate business interests; or
- Compliance with our legal obligations.
- 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 (for example, by posting a comment to a blog post or a webinar chat) 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 User Accounts, processing credit card payments, and collecting customer research or satisfaction surveys. They have access to the personal information needed to perform their functions.
d. Online Advertising Services
We use third-party advertising services, like Facebook® and Instagram®, 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.
- KEEPING YOUR INFORMATION SECURE
The transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Platforms or over email; any transmission is at your own risk.
5. YOUR RIGHTS
You have rights in relation to the personal information we hold about you. Below is an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. 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.
a. Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Platforms
- Marketing Email Communications: You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all marketing email messages from us or by contacting us here.
- Transactional or Service Email Communications: Some communications from us are considered transactional or service communications (for example, important account notifications, product updates, and billing information), and your Company products and services are provided to you upon the condition that you receive these communications from us. If you do not wish to receive any transactional or service communications from us, you must cancel your User Account for Company products and services. To cancel your User Account, you can mark this preference in your Account Settings. You may still receive marketing communications from us even after you cancel your User Account unless you also opt-out of our marketing communications, as described above.
- Navigation Information: You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
- Cookies: To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages referenced above under “Cookies and Similar Tracking Technologies.”
b. Accessing, Updating, Transferring and Deleting Your Data
- To update your personal information, please contact us here. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required.
- If you wish to access any personal information we hold about you, or to request that we delete or transfer any information about you that we have obtained, you may contact us here. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.
- At any time, you may object to the processing of your personal information, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us here. You also may have a right to lodge a complaint with data protection authorities.
- THIRD-PARTY SITES
The Platforms may contain features or links to web sites 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.
- DATA TRANSFERS
In order for us to provide the products and services to you, your personal information will be stored and processed in the United States. Where data is shared with third-party data processors, your data will be captured, transferred, stored and processed in accordance with their policies, practices and in compliance with their local regulatory laws.
- DATA RETENTION
We will retain your information for as long as your account is active, as necessary to comply with our legal obligations, to resolve disputes, and enforce our agreements. If you wish to delete your information, please contact us here.
- 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 here.
- 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, send an email to us here with the phrase “California Shine the Light” and include your mailing address, state of residence, and email address.
Since the internet industry is still working on Do Not Track standards, solutions, and implementations, we do not currently recognize or respond to browser-initiated Do Not Track signals.
- 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.
Your continued use of the Platforms after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
- HOW TO CONTACT US