Last revised: 4/02/2021
2. How do we obtain your consent?
1) access or use of this web site;
2) select and register for an offer(s) on this web site by clicking the offer(s) presented;
3) sign up for services such as coaching;
4) provide us with personal information to become a learner on our site, make a purchase, or participate in a course;
5) participate in a voluntary survey; and/or
- If you are a resident of the EU, please see “GDPR” as you may have additional rights.
- California residents, please also see the “Note to California Residents” section for additional rights.
3. How do you withdraw your consent?
4. What information do we collect and what do we do with it?
Basic contact and billing information:
- Your name and email address – to deliver the service or product that you requested and to send reminders (prior to an event or appointment that the user has registered for)
- Your name, email address, mailing and/or billing address, phone number, credit card number and expiration — when you purchase a product, course, or service from us.
- Recipient’s name, email/mail address, and phone number: — in the case that you complete an online gift order, schedule a coaching appointment, or singn up for courses, subscriptions or other offers requiring payment information.
Coaching information – to fulfill contractual agreements with you, provide superior service and meet legal and ethical requirements related to our coaching services.
- Includes intake information of a more personal nature, self-assessment data and results, coaching notes, financial or business information, and other data related to the actual process of personal or business coaching.
- This information is kept in the highest confidence and used to deliver the best possible service to you. Coaching records are kept in an Electronic Health Records (EHR) application (provided by Jane Software, Inc.) with bank-level encryption.
Information and Feedback You Provide in Forums/Blogs/Email/Discussion boards, Volunteer Surveys & Interviews – to help improve our services, marketing research and to collect data on what product or services we should offer or develop in the future.
Technical/Statistical information – We also collect and store information that is generated automatically when you browse our site. This includes:
- IP address (Internet Protocol Address used to connect your computer to the internet) — to prevent fraud, diagnose problems with the servicer, geographical location from which you accessed our website, etc.); information from cookies, information about your computer or device (e.g., device and browser type); information about how you use our website (e.g., which pages you have viewed, the time when you view them and what you clicked on; company name or business name (if applicable); and your answers to online quizzes and assessments we provide. This allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site.
The above information helps us improve our Site and facilitates your online experience when accessing our Site.
5. Other ways we may use this information
- Communication with Online learners: learners may receive emails about registration, their course content, changes to the course, course progress or other updates, the course Site itself and related course(s). Your email may also be used survey you about your usage, or collect your opinion – such as in giving course feedback or future courses you would like to see.
- Data Profiling & Research: IMPOWER is constantly trying to improve our products, services, communication and other aspects of our business. As such, we collate statistics or informative summaries about topics such as (but not limited to) customer behaviors, interests, booking patterns, and trends. We may use this information to find other customers like you or to make automated decisions based on any findings, for example sending you marketing emails with content related to a prior purchase that you might be interested in.
In terms of research, we may aggregate (combine) this information and strip it of personally identifying information to create broad categories including demographics, which may be shared with our audience or with other 3rd parties for educational, statistical, and/or marketing purposes.
- Hiring: In the event that IMPOWER considers an individual for employment or as an independent contractor, additional Personal Data may be collected. Specific data will vary depending on the position. Please contact firstname.lastname@example.org for more details.
IMPOWER may use and disclose information for the following purposes:
- To You – to communicate with you or to fulfill any contracts we enter with you;
- Operations – this includes various office, administrative, accounting, and business functions that support this practice’s ability to operate smoothly and provide superior service. Disclosure to these third parties is done only to the extent necessary to run our business;
- Payments – to provide information necessary to submit bills to a third party responsible for payment of services provided to you. Generally this will be your full name, email address, billing address and credit card information;
- Professional Consultation Support & Education – in order to make decisions about and support your wellness, life, and business goals your coach or instructor may consult about your case with other practitioners in order to gain insight or helpful tools for you or for their own professional development. Also, because IMPOWER is an educational business, we may share anonymous details for teaching or educational purposes or combine similar cases into vignettes. In either case, we will make every effort to not include any information which could be considered personally identifying so that we can hold a safe container for your healing and growth.
- Legal Reasons — as required by federal, state, or local law; or due to lawsuits and disputes (such as in response to a court or administrative order)
- Public Safety – when necessary to protect the rights, property or safety of users of the Site or the public.
- If there are persons involved in your care or payment for you care (you may agree or object to sharing information).
We take every precaution to protect our users’ information. When users submit sensitive information via the Website, all information is protected both online and offline.
Please be advised that, although we take every reasonable technological precaution available to protect your data, we cannot completely ensure or warrant the security of any information transmitted to us as no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we can make no assurances about our ability prevent any loss, misuse, or alteration to the information obtained from you or to any third party arising from any such loss, misuse or alteration.
Please ensure that you take all necessary precautions to protect your personal information while online.
We use a third party payment processor such as Stripe or Paypal. In some cases the third party payment processor will be integrated into a third party application. (For example, Stripe is integrated into Jane, and Stripe and Paypal are integrated into Thinkific and New Zenler.) In all cases, payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.
For more information on our payment processing please see “Payments” under “Third Party Applications.”
Information You Provide in Forums – Please note that if you give out personal information online through a discussion board, blog or other posting site, that information can be collected and used by third parties. Although we strive to protect our users’ privacy, we cannot guarantee the security of information you post in these forums. Please consider wisely what you choose to share.
8. Your privacy and third party services
We Use 3rd Party Services
The Site also includes links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control:
- In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
- This includes payment gateways and other payment transaction processors, who also have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
- For these third party providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
- Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada or the EU and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
COOPERATIVE PARTNERS/AFFILIATES/SALE OF ASSETS
- We may also make some content, products and services available through our Site or by emailing messages to you through cooperative relationships with third-party providers, where the brands of our provider partner appear on the Site in connection with such content, products and/or services.
- Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our websites is acquired by another company, information about our users may be among the transferred assets.
THIRD PARTY SERVICES WE USE
Below is a list of the Third Party Services we use to collect data and why:
Facebook Tracking Pixel
- An analytics tool that measures the effectiveness of our advertising by understanding the actions people take on our Website. The collected data remains anonymous.
- Personal Data collected: Cookies and Usage Data
Google Analytics (Google Inc.)
- Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
- Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
- Personal Data collected: Cookies and Usage Data.
Convertkit, LLC or Mailchimp (A registered trademark of The Rocket Science Group)
- All email contact information (email address, first name) is stored by the Convertkit or Mailchimp email service which delivers our newsletters and Direct Email Marketing. Your information can only be accessed by those who help manage those lists in order to deliver e-mail to those who would like to receive IMPOWER’S newsletters.
- All of the newsletters that are sent to you by IMPOWER include an “unsubscribe” or “manage subscriptions” link. To see more about unsubscribing see “How do I withdraw my consent?”
- If you do unsubscribe from marketing or newsletter emails, you will still receive essential calls, SMS texts, or email communications regarding things such as appointments you have booked, information about products that you have purchased, or if you are affiliate – information regarding our affiliate programs.
- Janeapp is an Electronic Health Records (EHR) Application created by Jane Software Inc (“Jane”).
- Your personal and business coaching information is particularly sensitive and that is why we use an EHR [or a local device with firewall] to store your contact and billing information, intakes and coaching notes, plus other materials surrounding your coaching experience. Janeapp supplies the highest standard of encryption (the same as used for Medical or Bank records).
- Jane processes credit card information through an integration with Stripe. The information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, they follow all PCI-DSS requirements and implement additional generally accepted industry standards.
- “Jane”, is based in Canada however your data is stored on a secure US server. For Jane’s full updated security policies see: https://jane.app/guide/privacy-and-security/list-of-security-features
- Some courses may be hosted by Thinkific Labs Inc. (“Thinkific”). They provide us with the online course creation platform that allows us to sell our courses and products to you.
- Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.
- When you click on links on our course site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
- If you make a purchase via Thinkific, they use a third party payment processor such as Stripe or Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.
- All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
- PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.
- For more insight, you may also want to read Thinkific’s Terms of Service here https://www.thinkific.com/resources/privacy-policy/ or Privacy Statement here https://www.thinkific.com/resources/terms-of-service/.
Most courses and our course site are hosted by New Zenler (aka “Zenler”). Zenler collects data on behalf of clients accepted onto our platform in order to provide services to you. Zenler does not control this data they simply process it. Student data collected may include:
- Identity data relating to subscriptions or purchases of products on the site such as (name, title, billing address, delivery address, email, phone number, other contact and purchase details including your card info.)
- User data including data about how you use the course site and online services, and any data you publish (user name and password, products and services you are enrolled in and your course progress along with files uploaded, purchases or orders, your interests and preferences, discussions, quizzes, feedback and survey responses.)
- Tech data including how you use the site (IP address, login data, length of visit o pages on the website, page views, navigation paths, number of times the website is visited, time zone settings, email statistics (open/clicks/ views) and other technology on the devices you use to access the site.) [The source of this data is from Zenler’s site analytics tracking program.]
- Marketing Data that includes data about your preferences (in terms of marketing receives from the Zenler site and communication preferences.)
- The only other personal information Zenler receives is that shared by Impower – which would be limited to necessary operations of the platform.
When you make a purchase on our site, we use a third party payment processor such as Stripe or Paypal. Payment processing services enable us to process payments by credit card, bank transfer or other means.
- To ensure greater security, our Sites share only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
- Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
PayPal Inc. (aka “PayPal”)
- PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments using their PayPal credentials.
- Paypal links may be embedded into the Site or directly into 3rd party software, such as Thinkific and New Zenler our Learning Management System (LMS) software.
Paypal or Stripe via Thinkific (See “Thinkific” under “Data”)
- Paypal and/or Stripe payment services may be integrated into our online learning platform, Thinkific. (To learn more see “Thinkific” under “Data”) and via New Zenler (see “New Zenler” for more details).
Stripe via Janeapp (See “Jane” under “Data”)
9. Age of consent
10. California Privacy Rights
12. Contact us
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, contact our Privacy Compliance Officer at: email@example.com [preferred] or send a letter:
IMPOWER HEALING, LLC
5305 RIVER RD. N. STE B
KEIZER, OR 97303
For California Privacy Rights, please write, “Your California Privacy Rights” For GDPR related requests, please write, “GDPR.” For all other request, please write a clear statement of the request for most efficient response. For all requests, please include your name, street address, city, state, and zip code and email address for our recordkeeping purposes. We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly or that do not have complete information. To opt out of our email list: Go to item #3 towards the top, “How do you withdraw your consent?”
- Like many websites, we use “cookies” or other similar tracking technologies in order to obtain certain types of information when you access our Site, or our advertisements, or other content provided by us or by others on our behalf from other sites. The information collected does not usually directly identify you; oftentimes, the information is tied to a cookie ID, advertising ID, IP address, or similar online/device identifier.
- A Cookie is a small piece of data sent from a website and stored on the user’s computer for record keeping purposes. Cookies help websites remember information such as keeping track of what is in your shopping cart, user preferences, authenticating whether you are logged in or not, or tracking your browsing history (source: Wikipedia). https://en.wikipedia.org/wiki/HTTP_cookie
- A cookie cannot be read by a website other than the one that set the cookie. A cookie cannot pass on a computer virus or capture any of the Personally Identifiable information.
- The Site also may use web beacons (aka single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users who visit the Site or open HTML-formatted email messages.
- Personalize your experience with our Site;
- Improve the performance of our Site to provide you with a better user experience.
- Gather information including the date and time of your visits to our Site, the pages viewed, and the time spent at our Site.
- Control the display of advertisements;
- Help us customize our web content to your needs, deliver advertisements, identify how many unique users visit us, and track user trends and patterns.
- Help our website recognize a user’s browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site. This keeps you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before.
- Google Chrome
- Mozilla Firefox
- Internet Explorer
- Safari 5.0
- iPhone, iPad, + Other Apple Applications:
- Android phones http://timeread.hubpages.com/hub/How-to-delete-internet-cookies-on-your-Droid-or-any-Android-device
(this is provided at a place to start as there are many kinds of android phones)
- Flash cookies (applies to all browsers) http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
STRICTLY NECESSARY COOKIES
We use “analytics” cookies, which, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our Site and which parts of our Site are most popular. This helps us gather feedback so that we can improve our Site and offer the best user experience.
Cookies that record your visit to our Site, the pages you have visited, and the links you have followed. We will use this information to make our advertising more relevant to your interests, and we may also share this information with third parties for this purpose.
IMPOWER via Facebook
Helps us to target Facebook Marketing to people who have already visited our site when they are on Facebook or a platform powered by Facebook.
|_ga||Google Analytics||2 years||Assigns a randomly generated number to identify and distinguish unique user. It is used to calculate visitor, session and campaign data for the site’s analytics and performance measures|
|_gat||Google Analytics||session||Used to throttle the request rate – limiting the collection of data on high traffic sites or peak use times.|
|_gat_gtag_UA_104061886_1||Google Analytics||Provides us with data on unique browser visits to our website.||Analytics|
|_gid||Google Analytics||session||Records the start and end of each visit to our website.||Analytics|