Privacy Policy
Last Updated - MAY 2018
Herein, all reference to 'we' or any derivative thereof, refers to Natalie Smith and Jodie Burnham, their websites, and their products.

This page informs you of our policies regarding the collection, use and disclosure of personal information when you engage with our websites and products.

We will not use or share your information with anyone except as described in this privacy policy.

We use your personal information for providing and improving our service. By engaging in our website or purchasing our products, you agree to the collection and use of information in accordance with this policy.


DEFINITIONS & LEGAL REFERENCES
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through our websites (or third-party services employed in our websites), which can include: the IP addresses or domain names of the computers utilized by the Users who use our websites, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User
The individual using our websites who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of our websites. The Data Controller, unless otherwise specified, is the Owner of our websites.

Our Websites (or this Application)
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by our websites as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.


INFORMATION COLLECTION & USE:
We may collect two different types of information; personally identifiable information (“PII”) and non-personally identifiable information (“non-PII”). PII is information that identifies you as an individual, for example your name, address, telephone number, email address, credit card information, billing address and shipping information. Non-PII is aggregated information, demographic information, IP addresses, user behavior data from web interaction metrics tools and other information that does not reveal your specific identity. PII and non-PII may be collected anytime you access or use one of our websites. PII and non-PII may also be collected by us during in-person discussions, telephone conversations, and electronic or other written communications. We also collect information via cookies; blocking cookies may render you unable to access certain products, services, or websites.

We use PII to respond to your inquiries, provide you with services you have requested, keep you informed of services we think may be of interest to you, and otherwise personalize your experience with us, and other reasons. We do not sell or lease PII about you to others. We may share PII with our affiliates and third parties contracting with us to provide services to you. We may also share PII when required by law, or when you have expressly requested us to do so. We reserve the right to disclose and use your PII if we believes it is necessary to: (a) respond to legal process, e.g., a subpoena; (b) respond to a law enforcement agency’s request; (c) enforce the terms; or (d) protect the rights, privacy, safety, property, or operations of ourselves or third parties.

As non-PII does not personally identify you, we reserve the right to use and disclose to this information to third parties for any purpose.

We maintain reasonable physical, administrative and technical safeguards to protect PII from loss, misuse, or unauthorized access, disclosure, alteration or destruction. We enforce our privacy policy via self-assessment.

Information, Registration, User Names and Passwords:
As a member or user of our products, you will be required to create an account with us. You warrant that the information you provide us is truthful and accurate, and that you are not impersonating another person. You are responsible for maintaining the confidentiality of any password you may use to access your account, and you agree not to transfer your password or username, or lend or otherwise transfer your use of or access to your account, to any third party. You are fully responsible for all transactions with, and information conveyed to us, under your account. You agree to immediately notify us of any unauthorized use of your password or user name or any other breach of security related to your account. You agree that we are not liable, and you will hold us harmless, for any loss or damage arising from your failure to comply with any of the foregoing obligations.

Log Data:
We collect information that your browser sends whenever you visit our service ("log data"). This log data may include information such as your computer's internet protocol ("IP") address, browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Facebook or Google Analytics that collect, monitor and analyze this type of information in order to increase our functionality. These third party service providers have their own privacy policies addressing how they use such information.

Facebook Pixels:
We have a Facebook Pixel on every landing page of our websites. The Facebook pixel collects PII data, and transfers it to Facebook for our use in Facebook advertising. We do not gain any access to your PII data during this process. For more information, please see the Advertising section below.

Cookies:
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.

We use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.

Do Not Track Disclosure:
We support do not track ("DNT"). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.


DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA:
Personal Data is collected by our websites for the following purposes and using the following services:

Analytics:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Contact form:
By filling in the contact form with their Data, the User authorizes any website owned by us to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address and first & last names.

Email Mailing list:
By registering on the mailing list for one of our opt-ins, free or otherwise, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning our websites and products. Your email address might also be added to this list after making a purchase. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email or message we send, or by contacting us HERE

Personal Data collected: email address and first & last names.

Actionetics (Etison LLC):
The Actionetics widget is a service for interacting with the Actionetics email address management and message sending service provided by Etison LLC.

Personal Data collected: Cookies, email address, first & last name, and Usage Data.

Place of processing: United States – Privacy Policy.

Managing Contacts and Sending Messages:
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Handling Payments:
Payment processing services enable our websites to process payments by credit card, bank transfer or other means. To ensure greater security, our websites 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 (PayPal Inc.):
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy.

PayPal button and widgets (PayPal Inc.):
The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: See the PayPal privacy policy.

Stripe (Stripe Inc):
Stripe is a payment service provided by Stripe Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Displaying Content from External Platforms:
This type of service allows you to view content hosted on external platforms directly from the pages of our websites and interact with them.This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Interaction with data collection platforms and other third parties:
This type of service allows Users to interact with data collection platforms or other services directly from the pages of our websites for the purpose of saving and reusing data. If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of our websites.The interaction and information obtained through our websites are always subject to the User’s privacy settings for each social network.This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Advertising:
This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on our websites, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside our websites. For more information, please check the privacy policies of the relevant services.

In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

Personal Data collected: email address.

Remarketing and behavioral targeting:
This type of service allows our websites and partners to inform, optimize and serve advertising based on past use of our websites by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

Facebook Custom Audience (Facebook, Inc.):
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of our websites with the Facebook advertising network.

Personal Data collected: Cookies and email address.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Facebook Remarketing (Facebook, Inc.):
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of our websites with the Facebook advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.


BACK-END INFRASTRUCTURE:
Service Providers
We may employ third party companies and individuals to facilitate our service, to provide the service on our behalf, to perform service-related services or to assist us in analyzing how our service is used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. These include:

Hosting: Clickfunnels
Personal Data: Various types of Data as specified in the privacy policy of the service, necessary to display our websites to the user.

Scheduling Tool: Calendly
Personal Data: first name, last name, email address and payment details, where necessary in order to book a call or schedule an appointment in order to receive consulting or other services as stated.

Providing Course Material: ClickFunnels
This type of service allows users to get access to online course material offered through our websites. For that reason, specific data has to be collected in order to fulfill that service.

Personal Data collected: Cookies, email address, first name, last name and Usage Data.

Place of processing: United States - Privacy Policy

Selling goods and services online:
The Personal Data collected is used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by our websites depends on the payment system used.


RETENTION TIME:
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:
 * Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

 * Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.


THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:


Withdraw their consent at any time.
Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing of their Data.
Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.

Further details are provided in the dedicated section below.

Access their Data.
Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification.
Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of their Data.
Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

Have their Personal Data deleted or otherwise removed.
Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller.
Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

Lodge a complaint.
Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing.
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.


ADDITIONAL LEGAL INFORMATION
Compliance With Laws
We will disclose your personal information where required to do so by law or subpoena, or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement, or to protect the security or integrity of our service.

Business Transaction
If we are involved in a merger, acquisition or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

Security
The security of your personal information is important to us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

International transfer
Your information, including personal information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Links to Other Sites
Our service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

We are affiliated and associated with various operators of third party websites that link to or are linked from websites maintained by us. We disclaim any responsibility for the accuracy or content of information found on third party websites that link to or are linked from any of our websites. We disclaim any responsibility for the security of any information (including, without limitation, credit card and personally identifiable information (“PII”)) that you may provide to any third party. We reserve the right, at any time and in our sole and absolute discretion, to block links to any website maintained by us through technological or other means without prior notice.

Release and Authorization to Use Photographs
You grant us permission to use any and all photographs, or video, or audio, or digital recordings, taken by us or our agents or employees, or submitted by you to us (hereinafter “photographs”) in any media (including print, internet, film, television and no matter how distributed or published) for any purpose, which may include, but shall not be limited to, advertising, promotion, marketing and packaging of any product or service sold and marketed by us. You agree that this authorization to use photographs may be assigned by us to any other party. You agree that the photographs may be combined with other photographs, sounds, text and graphics, and that the photographs may be manipulated, cropped, altered or modified in our sole discretion. You agree not to charge a royalty or fee, and not to make any other monetary assessment against us in exchange for this release and assignment. You hereby release and forever discharge us from any and all liability and from any damages you may suffer as a result of the use of the photographs. You further acknowledge and agree that this release is binding upon your heirs and assigns. You agree that this release is irrevocable.

Children's privacy
Our service does not address anyone under the age of 13 ("children"). We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your child/ren has provided us with personal information, please contact us. If we discover that a child under 13 has provided us with personal information, we will delete such information from our servers immediately.

Preparation of this Privacy Policy
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

Changes to this Privacy Policy
We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page. You are advised to review this privacy policy periodically for any changes. Changes to this privacy policy are effective when they are posted on this page.


Thanks so much for visiting.

If you have any questions about our privacy policy, please connect with us HERE and we’ll get right back to you.

Kind Regards,
Nat and Jodie

natnjodie.com

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