PRIVACY POLICY

Introduction

Jessica Sitomer, PassionPreneur AKA The Greenlight Coach, Inc. (“TGC”) provides educational materials, information relating to Jessica Sitomer (The Greenlight Coach), business training, and business products on the www.TheGreenlightCoach.com and related websites (the “Site”). Our content includes information about Jessica Sitomer and her various endeavors, products, events, photos, video, podcasts, articles, books, television appearances and interactivity with our users, and also provides links to other Jessica Sitomer and Greenlight Coach sites. While we encourage the interactive nature of our website, we strive to promote the online safety and privacy of our users.

We have implemented this Privacy Policy governing the personally identifiable information (“Personal Consumer Information”) collected by this Site. This Privacy Policy does not govern Personal Consumer Information collected from any other source or in any other manner.

Overview

This Privacy Policy is intended to provide you with information as to: (i) the type of information that is collected, (ii) how collected information is used and with whom it is shared; (ii) how we intend to protect the information; and (iii) how you can access, modify and/or delete such information.

This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://jessicasitomer.com

By providing us with your data, you warrant to us that you are over 13 years of age.
Linda Beach is the data controllers and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: The Greenlight Coach, Inc.

Email address: info@theGreenlightCoach.com

Postal address: 110 S Fairfax Ave Ste A110 Los Angeles, CA 90036

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@theGreenlightCoach.com

What Data Do We Collect About You, For What Purpose And On What Ground We Process It

Information You Provide to Us: We may collect information about you when you visit and interact with this Site. Some of this information may be automatically collected, and some is collected when you interact with the Site. The type of information that may be automatically collected may include date and time of access of the Site, the Internet protocol address of the computer that you are using, the domain and host from which you access the Internet, your browser software and operating system, and the specific activities you are engaged in while visiting the Site.

Information from which you can be personally identified may also be collected by us at the Site, including your name, postal address, email address, telephone number, and credit card number (referred to as “Personal Consumer Information”) and/or any other identifier that permits the physical or online contacting of you in connection with your use of, or participation in any of the following: membership registration at TheGreenlightCoach.com contests, sweepstakes, promotions, surveys, forums, subscription registrations, content submissions, chats, bulletin boards, discussion groups, requests for suggestions, visitors’ requests for free products or services or additional information (including via email to us) and in connection with other activities, services or resources we make available on any of our Sites. In all these cases, we will collect personal consumer information from you only if you voluntarily submit such information to us. Further, “TGC” may contact you based on the information you provide online whether in connection with your registration or in such places as the above described forums.

Of course, you may choose not to provide certain information to us, but if so, you may not be able to participate in certain of the activities and transactions available at the Site.

What information do we collect? We may process the following categories of personal data about you:

Communication Datathat includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Datathat includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Datathat includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Datathat includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Datathat includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Datato deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

California Online Privacy Protection Act Compliance: Because we value your privacy we have taken the necessary precautions to protect your privacy as outlined in this privacy policy. As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at any time by emailing us at info@theGreenlightCoach.com

Children’s Online Privacy Protection Act Compliance: We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are adult business owners.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@theGreenlightCoach.com . In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

How We Collect Your Personal Data

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy below for more details.

We may receive data from third parties such as analytics providers such as Google, advertising networks such as Facebook based, such as search information providers such as Google, providers of technical, payment and delivery services, such as data brokers or aggregators.

How Your Information Is Used

Any of the information we collect from you may be used in one of the following ways:

To personalize your experience.Your information helps us to better respond to your individual needs.
To improve our website.We continually strive to improve our website offerings based on the information and feedback we receive from you.
To improve customer service.Your information helps us to more effectively respond to your customer-service requests and support needs
To process transactions.Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
To administer a contest, promotion, survey or other site feature.
To send periodic emails.The email address you provide for order processing may be used to send you information and updates pertaining to your order. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@theGreenlightCoach.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

Shopping

When you seek to shop for products on this Site, this Site may collect information about its users to help improve your shopping experience or to make occasional product or service offers for which you may be interested.

Disclosures Of Your Personal Data

We may have to share your personal data with the parties set out below:

Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers.
Government bodies that require us to report processing activities.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA), like Stripe, Mailchimp, Thinkific, WebinarJam, PayPal, etc., for example which reside in the United States.

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@theGreenlightCoach.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies

Do we use cookies? Yes.

Use of “Cookies” and Other Technologies: We may use “cookies” and/or other technologies or files (collectively, “cookies”) to identify how visitors make use of this Site. This aggregate tracking information may be used to help us improve and enhance the website experience for all of our visitors. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We use Conversion Tracking for our ads and often create Custom Audiences from our website for advertising purposes, and these (a) third parties may use cookies, web beacons, and similar technologies to collect or receive information from our website and elsewhere on the internet and use that information to provide measurement services and target ads, (b) however you can opt-out of the collection and use of information for ad targeting, and (c) this is a website here you can access information on how you can opt out: www.aboutads.info/choices.

Cookies Information

Security of Information

We at “TGC” use reasonable standards of confidentiality and security for this Site and for the Personal Consumer Information collected from this Site. The Personal Consumer Information you provide is secured using industry standard e-commerce security technology. We also restrict our own employees’ access to Personal Consumer Information. However, it is possible that someone may intercept or access communications, transmissions and/or Personal Consumer Information. You must also seek to protect against unauthorized access to any information that you use in connection with this website, and you should remember to close the browser once you have completed your activities on the Site or if you have decided to step away from your computer. In the event that we determine that there has been a security breach resulting the unauthorized disclosure of Personal Consumer Information to a third party, we will notify consumers whose Personal Consumer Information has been so disclosed by posting such information on the Site and, if email contact is possible, then we would send an email advising of the status.

Use and Sharing of Personal Consumer Information

Except as otherwise provided in this policy, we reasonably attempt to ensure that we never intentionally disclose any personal consumer information about you as an individual user to any third party without having received your permission (through opting in or similar procedures) except as provided for herein or otherwise as permitted or required under law.

We have the following exceptions to this policy: We will release specific information about you or your account to comply with any valid governmental inquiry or legal inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if there is an attempted breach of the security of the Sites or a physical or property threat to you or others. We may also transfer user information, including personal consumer information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate change. We may provide access to your personal consumer information to our contractors who are performing services for us in connection with our Sites or the services that you have requested.

In addition, on occasion, we may collect personal consumer information from you in connection with optional contests, special offers or promotions. We will share such information with necessary third parties for the purpose of carrying out the contest, special offer or promotion. Your participation in the contest, special offer or promotion constitutes your consent to such disclosure and use of such information.

Further, the information you enter when making a purchase will be shared with payment processors, financial gateways and your credit card company to authorize credit card payments. Such information may also be shared with necessary third parties solely for the purpose of carrying out the transactions.

Please note that if you give out personal information online—for example, on one of our public forums such as a message board — 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 and have no control over how such third parties may use your information. You disclose such information at your own risk.

You are responsible for the confidentiality of your information and password. You shall be responsible for all uses of your registration, whether or not authorized by you. You agree to immediately notify us of any unauthorized use of your registration or password.

Sharing of User Content on the Site

When users send us stories, photos and/or other User Content, these materials may be posted on our Site. We will not return any materials, such as photographs, once they have been sent to us. If you would like them removed, email info@theGreenlightCoach.com

Accessing Your Information

You may update and/or correct the Personal Consumer Information collected on the Site, or seek to have such information deleted from our records, by us emailing us at info@TheGreenlightCoach.com

Linked Sites

From time to time, the www.TheGreenlightCoach.com website may provide links to other websites that are not controlled and/or owned by “TGC.” Please be aware that these other websites may have different privacy policies that may subject you to different privacy practices. Please review the privacy policies of such other websites for information concerning what information is collected on such sites and how it is used.
Your Consent: By using this website, you consent to our privacy policy.

Changes in Policy

From time to time, this Privacy Policy may change. We will post changes to the Privacy Policy at this Site. Please review this Privacy Policy often so that you will be aware of “TGC’s” current policies, including our policies concerning the gathering and use of information that may be collected on our Site. If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date stated below.

Contact Us

If you have any questions concerning this Privacy Policy, please send us an email at info@theGreenlightCoach.com

Governing Law

This Privacy Policy shall be governed by the laws of the State of California, without regard to its conflict of law provisions. Any dispute concerning this Privacy Policy or your use of this Site shall be submitted to binding arbitration in California within one (1) year from the date that the cause of action arose (or, if multiple cause of actions are involved, from the date that the first cause of action arose), with such arbitration conducted pursuant to the then prevailing rules of the American Arbitration Association. To the fullest extent permitted by law, no arbitration brought pursuant hereto shall be joined to any other action or any other arbitration initiated pursuant hereto. If any portion of this Privacy Policy is deemed unenforceable, unlawful or void by a Court of competent jurisdiction, then that portion of the Privacy Policy will be deemed severable and will not affect the enforceability or validity of the remaining portions of this Privacy Policy.