Strong with Purpose LLC Privacy Policy
(Effective as of November 2016)
Definitions
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – Strong with Purpose LLC
Who we are
Our website address is: https://www.strongwithpurpose.com.
Data Protection Principles
We promise to follow the following data protection principles:
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Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
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Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
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Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
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Processing is limited with a time period. We will not store your personal data for longer than needed.
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We will do our best to ensure the accuracy of data.
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We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
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Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
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Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
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Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
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Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
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Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
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Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
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Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
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Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
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Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
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Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
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Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
Information you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address. We collect this information from you when you register on our site, place an order, subscribe to a newsletter, fill out a form or enter information on our site and during the checkout process on our store.
Forms
We use MailChimp as our marketing automation platform.
By submitting a form to us, you acknowledge that the information you provide will be transferred to MailChimp for processing in accordance with their
Privacy Policy and
Terms.
Comments
When visitors leave comments on the site, an anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
While you visit our site, we’ll track:
Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed
Location, IP address and browser type: we’ll use this for purposes like estimating taxes and shipping
Shipping address: we’ll ask you to enter this so we can, for instance, estimate shipping before you place an order, and send you the order!
We’ll also use cookies to keep track of cart contents while you’re browsing our site.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
Publicly available information
We might gather information about you that is publicly available.
How we use your Personal Data
We use your Personal Data in order to:
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provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
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enhance your customer experience;
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fulfil an obligation under law or contract;
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giving you access to provided course materials;
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allow you to make store purchases;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
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to send you personalized offers* (from us and/or our carefully selected partners);
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to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
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to conduct questionnaires concerning client satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
We process visitor comments through an automated spam detection service.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
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the link between purposes, context and nature of Personal Data is suitable for further Processing;
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the further Processing would not harm your interests and
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there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share your data with:
Our processing partners:
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We accept payments through PayPal and Stripe. When processing payments, some of your data will obviously be passed to PayPal or Stripe (depending on the processor you choose / is provided at checkout), including information required to process or support the payment, such as the purchase total and billing information.Please see the
PayPal and
Stripe Privacy Policies for further details.
Third Party Links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We audit, fence and monitor our systems for and against possible vulnerabilities and attacks.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
If you have an account with us, note that you have to keep your username and password secret.
Cookies and other technologies we use
We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
We use cookies for the following purposes:
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Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
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Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
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Analytics cookies – these cookies are used to track the use and performance of our website and services
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Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review
here. If you’d like to opt out of tracking by Google Analytics, visit the
Google Analytics opt-out page.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
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Send information, respond to inquiries, and/or other requests or questions
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Process orders and to send information and updates pertaining to orders
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We may also send you additional information related to your product and/or service
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Market to our mailing list or continue to send emails to our clients after the original transaction has occurred
To be in accordance with CANSPAM we agree to the following:
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NOT use false, or misleading subjects or email addresses
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Identify the message as an advertisement in some reasonable way
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Include the physical address of our business or site headquarters
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Monitor third party email marketing services for compliance, if one is used
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Honor opt-out/unsubscribe requests quickly
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Allow users to unsubscribe by using the link at the bottom of each email
If at any time you would like to unsubscribe from receiving future emails, you can
and we will promptly remove you from ALL correspondence.
COPPA (Children Online Privacy Protection Act)
We do not intend to collect or knowingly collect information from children. We do not target children with our services, and we do not specifically market anything to children under 13.
CalOPPA
According to CalOPPA we agree to the following:
Users can visit our site anonymously
Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.
Users are able to change their personal information:
How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third party behavioral tracking?
It’s also important to note that we allow third party behavioral tracking
Contact Information
If you have any questions about what is present in this privacy policy, Strong with Purpose LLC can be reached via email at kristen@strongwithpurpose.com.
Representative Contact in the EU
Supervisory Authority
Phone: +353 57 868 4800
Changes to this Privacy Policy
We reserve the right to make change to this Privacy Policy.
Last modification was made August 27, 2018.