Online Privacy Policy - General Data Protection Regulation Compliant

Effective Date: February 2021

This privacy policy outlines what information (“PERSONAL DATA”) is collected from you (“SUBSCRIBER”) and how that information is handled by Sarah Gleeson Group of Companies and, Sarah Gleeson International (the “COMPANY”). All is done in accordance with the recent General Data Protection Regulation (GDPR).

Summary: The COMPANY provides various ways for you to add your personal information to their database. By clicking on “Submit” “Sign-up” “Buy now” “Purchase” and or any other button that has a similar meaning you are providing your explicit consent to be added to the COMPANY’s communication system. The COMPANY may use any reasonable means of communicating with you based on the information you provide. You may opt-out of this at any time by clicking on the “unsubscribe” button included on all email communication.

Sarah Gleeson Group of Companies (the “COMPANY”) respects the privacy concerns of the users of its websites www.sarahgleesoninternational.com and the services and or goods provided there (the “SITE”). The COMPANY provides this privacy statement to explain what information is gathered during a visit to the SITE and how such information may be used.

Please also review the Terms of Use at www.sarahgleesoninternational.com/pages/terms which also govern your use of this SITE.

USE OF INFORMATION

As a general policy, no personally identifiable information (“PERSONAL DATA”), such as your name, address, or e-mail address, is automatically collected from your visit to the SITE. ANY PERSONAL DATA COLLECTED BY THE SITE MUST BE VOLUNTARILY ENTERED BY THE SUBSCRIBER.

Non-personal data is recorded by the standard operation of the COMPANY’S internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.

PERSONAL DATA is information that specifically identifies you (name, email address, ship to/bill to address, phone number) and can be used to specifically locate you from within the COMPANY’S database and or filing system.

The SITE’S various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give the COMPANY contact information such as your

Name,
Email,

Information submitted at the time of submission will be used by the COMPANY to:

To communicate with you regarding products you have purchased, send you my blogs or to send other interesting and helpful business related info
Email SUBSCRIBER the requested information from the COMPANY;
Email SUBSCRIBER an occasional newsletter from the COMPANY;
Provide SUBSCRIBER access to the requested content from the COMPANY;

PERSONAL DATA submitted voluntarily by the SUBSCRIBER is held:

Within the COMPANY’S Kajabi SITE and database and/or on the COMPANY’S CRM;
Until the SUBSCRIBER requests to be unsubscribed and or up to two years from the time of submitting, whichever comes sooner;
The COMPANY will ask SUBSCRIBER every two years if he or she wants to continue as a SUBSCRIBER to the COMPANY

LEGAL BASIS FOR USE OF INFORMATION

The COMPANY is legally processing SUBSCRIBER’S PERSONAL DATA based on the following: CHOOSE THE ONES THAT ARE APPLICABLE AND REMOVE THE OTHERS

The SUBSCRIBER has given his or her explicit and voluntary consent to the COMPANY;
Hosting clients of the COMPANY have a contract with the COMPANY that necessitates the COMPANY having his or her PERSONAL DATA;

USE TO THIRD PARTIES

PERSONAL DATA is never sold, leased, or shared with any third parties. A third party is a COMPANY outside of the SUBSCRIBER - COMPANY relationship.

USE TO CREDIT CARD INFORMATION

The COMPANY does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.

All credit card information is handled by Stripe, PayPal, or other security credit card processors.

USE LEGAL OBLIGATIONS

The COMPANY may disclose SUBSCRIBER information in special cases when required by legal and or law enforcement and only when required by law.

If the COMPANY has reasonable reason(s) to believe that disclosing PERSONAL DATA held by the COMPANY is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the COMPANY’S rights or property, other users of the SITE, and or anyone else that could be harmed by such activities, then the COMPANY will work with the appropriate and legitimate law enforcement and or legal authorities to make sure that the PERSONAL DATA is handled in accordance with the applicable laws.

SUBSCRIBERS RIGHTS

As a subscriber and/or user of the SITE, you have the following rights:

Transparent information from the COMPANY regarding how they communicate and interact with the SUBSCRIBER;
The right to hear back from the COMPANY regarding any inquiry into SUBSCRIBER’S PERSONAL DATA;
To request correction of PERSONAL DATA from the COMPANY;
Access to SUBSCRIBER’S PERSONAL DATA including knowing the purposes that the data is used for;
To request erasure from the COMPANY’S records provided that there are not overriding legal, public interest, or legitimate interests;
To a restriction on the processing of the PERSONAL DATA;
Data portability of PERSONAL DATA (having a record provided to you that is readable and commonly used that outlines the PERSONAL DATA the COMPANY has on you)
To object to processing of PERSONAL DATA - the COMPANY shall no longer process the SUBSCRIBER’S PERSONAL DATA unless the COMPANY demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the SUBSCRIBER or for the establishment, exercise or defence of legal claims.
To file a complaint with the supervisory authority;
The right to unsubscribe at any time (withdraw consent)

PROFILING PERSONAL DATA

Profiling means any form of automated processing of PERSONAL DATA consisting of the use of PERSONAL DATA to evaluate certain personal aspects relating to a SUBSCRIBER, in particular, to analyze or predict aspects concerning that SUBSCRIBER’S performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;

The COMPANY DOES NOT ENGAGE IN ANY SORT OF PROFILING OF ITS SUBSCRIBERS BASED ON PERSONAL DATA.

CHILDREN UNDER AGE 13

The COMPANY recognizes the special obligation to protect PERSONAL DATA obtained from children age 13 and under.

IF YOU ARE 13 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY.

If the COMPANY discovers that a child age 13 or younger has signed up on the SITE and or provided the COMPANY with PERSONAL DATA, the COMPANY will delete that child’s PERSONAL DATA from our records.

The COMPANY nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:

Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
Know the sites your kids are visiting and which sites are appropriate.
Look for Website privacy policies. Know how your child’s information is treated.
Check out the Federal Trade Commission’s (FTC) site for more tips on protecting children's privacy online

USE OF COOKIES

Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using the COMPANY’S SITE easier by saving your passwords and preferences for you.

These cookies are restricted for use only on COMPANY’S SITE, and do not transfer any PERSONAL DATA to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions.

If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the SITE may not function properly or may be considerably slower.

The COMPANY uses the following cookies on the Kajabi SITE:

Cookie	Name	Purpose
_kjb_session	Kajabi session cookie	Tracks your active admin session so you don't need to re-login
kjba	Kajabi affiliate token	Tracks which affiliate has referred an offer purchase
_abv	Admin bar hidden	Tracks whether the user wishes their admin previewing bar to be hidden

MALWARE/SPYWARE/VIRUSES

Neither the COMPANY nor the SITE knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

LINKS TO EXTERNAL SITES

The COMPANY is not responsible for the content or practices of third-party websites that may be linked to the SITE.

The COMPANY is also not responsible for any information that you might share with such linked websites.

You should refer to each website’s respective privacy policy and practices prior to disclosing any information.

BULLETIN BOARDS AND CHAT AREAS

Guests of the SITE are solely responsible for the content of messages they post on the COMPANY’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.

OPT OUT OR REMOVAL OF YOUR INFORMATION

The SITE provides the SUBSCRIBER the opportunity to opt-in to receive communications from the COMPANY at the point(s) where PERSONAL DATA information is required to be voluntarily entered by the SUBSCRIBER.

The SUBSCRIBER always has the option of removing their PERSONAL DATA from any communications list in order to discontinue any such future communications.

In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the COMPANY, which you no longer wish to receive.

If you are unsuccessful in completing the instructions specified in any such communication, please email the COMPANY at [email protected] and simply request to unsubscribe.

Unsubscribe from all communications from the COMPANY
Unsubscribe from a specific set of communications from the COMPANY

SECURITY

Security for all PERSONAL DATA is extremely important to the COMPANY.

Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure.

As a result, while the COMPANY strives to protect SUBSCRIBER’S PERSONAL DATA, the COMPANY cannot ensure or warrant the security of any PERSONAL DATA the SUBSCRIBER transmits via the internet. By transmitting any such information to the COMPANY, SUBSCRIBER accepts that he or she does so at their own risk.

TRANSFER OF CUSTOMER INFORMATION

Customer lists and information are properly considered assets of a business. If COMPANY merges with another entity, or if it sells its assets to another entity, the COMPANY’S customer list and information would be included among the assets transferred.

SUBSCRIBER would be given the opportunity to unsubscribe both before and after the sale.

YOUR ACCEPTANCE OF THESE TERMS

By using the SITE, the SUBSCRIBER accepts the policies and restrictions set forth in this Online Privacy Policy. If you do not agree to this policy, please do not use the SITE. This Online Privacy Policy may be revised from time to time by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Online Privacy Policy to which you are bound.

Contact Us

If you have any questions, concerns or complaints about this Terms of Use, please contact us:

By email: [email protected]
By visiting this page on our website: https://www.sarahgleesoninternational.com/contact

California Supplemental Privacy Notice

THIS SUPPLEMENT IS FOR CALIFORNIA RESIDENTS ONLY

This California Supplemental Privacy Notice (“California Privacy Notice”) supplements the information contained in the Privacy Policy and applies solely to visitors, users, and others who are residents of the State of California. This section describes your rights under the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws. Any terms defined in the CCPA have the same meaning as when used herein.

While we have set out the categories below as required by the CCPA, you can review our Privacy Policy for examples and other information that describes our data collection and use, which will not change under this notice.

What is the CCPA?

The CCPA is a California law that provides California residents certain rights to their personal information.

California residents, called “consumers” in the CCPA, have the following rights:

The right to request that we disclose certain information to you about our collection and use of personal information over the past 12 months.
The right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions.
The right to opt-out of the sale of personal information by us.
The right not to receive discriminatory treatment by us for exercising the privacy rights conferred by the CCPA.

We will explain more about how to exercise these rights below.

When we talk about “personal information” under the CCPA, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. Personal information does not include publicly available information or information that is deidentified or aggregate consumer information. The CCPA does not apply to personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. It also doesn’t apply to health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

Scope of the California Privacy Notice.

The Company offers its services to be used by its customers and most of the personal information we process is done at their direction. This California Privacy Notice only describes our processing activities for data that we own and control. If you are a California resident interacting with our site as a subscriber to one of our customers’ businesses, all of your data is owned by such customer(s) and we recommend you contact them about their practices under the CCPA.

This California Privacy Notice does not apply to personal information we collect from employees or job applicants in their capacity as employees or job applicants. It also does not apply to personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services. Therefore, any responses pursuant to the CCPA may exclude those categories of personal information.

Information We Have Collected About Consumers in the Preceding 12 Months.

All of the categories of personal information we collect about you (as detailed below) come from the following categories of sources:

You, including through your use of our services and product;
Automatically collected from you; and
Third parties, such as when you give permission to social networks to share your information with us or where you have made your personal information publicly available online.

The following chart sets out the CCPA categories of personal information we have collected from consumers within the last twelve (12) months.

Categories of Personal Information We Collect	Categories of Third Parties with Which We May Share that Information
Identifiers (such as name, address, email address)	Third parties (such as our service providers and integration partners) or your organization (through its purchase of an Enterprise account with us) Our affiliate companies Aggregators (such as analytics services)
Commercial Information (such as transaction data)	Third parties (such as our service providers) Our affiliate companies Aggregators (such as analytics services)
Financial Data (such as billing information)	Third parties (such as our service providers and integration partners) Our affiliate companies
Internet or Other Network or Device Activity (such as browsing history or app usage)	Third parties (such as our service providers and integration partners) Our affiliate companies Aggregators (such as analytics services)
Location Information (e.g. inferred from your IP address)	Third parties (such as our service providers and integration partners) Our affiliate companies Aggregators (such as analytics services)
Professional or Employment-Related Data (such as the name of your employer)	Third parties (such as our service providers and integration partners) Our affiliate companies Aggregators (such as analytics services)
Legally Protected Classifications (such as gender and marital status)	Third parties (such as our service providers and integration partners) Our affiliate companies
Other Information that Identifies or Can Be Reasonably Associated with You	Third parties (such as our service providers and integration partners) Our affiliate companies Aggregators (such as analytics services)

‍The Purposes for Which Personal Information is Collected.

We may collect the personal information we collect for one or more of the following business purposes:

Providing our services (for example, branding, messaging and positioning, customer service, marketing, analytics, and communication about our services);
For our operational purposes, and the operational purposes of our service providers and integration partners;
Improving our existing product and services and developing new products and services (e.g., by conducting research to develop new products or features);
Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
Bug detection, error reporting, and activities to maintain the quality or safety of our services;
Auditing consumer interactions on our site (for example, measuring ad impressions);
Short-term, transient use, such as customizing content that we or our service providers display on the product;
Other uses that advance our commercial or economic interests, such as third party advertising and communicating with you about relevant offers from third party partners;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's business or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company is among the assets transferred; and
As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Sale of Your Personal Information.

The CCPA defines a “sale” of personal information as the disclosure, sharing, or making available of a consumer’s personal information by a business to another business or third party for monetary or other valuable consideration. It is not a sale if a consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party. The Company does not monetize your personal information. We share certain information about your device and interaction with our digital properties to enhance your experience with us and to engage in the legitimate business purpose of advertising and marketing.

The CCPA requires businesses that “sell” personal information to provide California residents the right to opt out from such sales. The Company does not “sell” your personal information as we understand that term to be defined by the CCPA and its implementing regulations. To the extent that you have taken the position that a website’s use of third-party cookies or similar technology for advertising or analytics constitutes a “sale” under the CCPA, you may consider the Company to have “sold” what the CCPA refers to as “identifiers” (e.g. IP addresses), “internet or other electronic network activity information” (e.g. information about an individual’s browsing activity on our website), and “commercial information” (e.g. the fact that a browser visited a webpage directed at individuals considering purchasing the Company's products or services). Please refer to our Privacy Policy for more information, including how to exercise your rights to opt-out or manage your cookie preferences.

Exercising Your California Privacy Rights.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. Agents must submit proof that they have been authorized by the consumer to act on their behalf. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We verify requests by sending a confirmation email to the requestor and by matching the identifying information provided by the consumer to the personal information already maintained by us. We cannot respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; and (ii) confirm the personal information relates to you. If we are unable to verify the identity of a consumer to a sufficient degree of certainty, we will deny the request and explain the reason for the denial.

If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us via [email protected].

You may only make a verifiable request for access or data portability twice within a 12-month period. California residents may exercise their California privacy rights by submitting your request to [email protected].

If you wish to exercise any of these rights and do not have an account with us, please contact us via: [email protected] and we will request additional information to perform identity verification where possible.

Other California Privacy Rights.

In addition to the CCPA, the California Civil Code permits California residents with whom we have an established business relationship to request that we provide you with a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please contact us at [email protected] and mention that you are making a “California Shine the Light” inquiry.