Last Updated: July 15, 2020
What Information Do we Collect and How Do We Collect It?
When you visit parts of the Services, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse parts of the Services, we collect information about the individual web pages that you view, what website or search terms referred you to the Services, and information about how you interact with the Services. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on parts of the Services, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Services.
In order to provide you with the Services and complete any purchases you make, the Services may collect personally identifiable information, such as your:
- First and Last Name;
- Mailing Address;
- E-mail Address;
- Phone Number;
- Job Title;
- Billing and Credit Card Information, such as credit card numbers, checking account number, bank wire, PayPal (collectively, “Order Information”)
The Services may also collect anonymous demographic information, which is not unique to you, such as your age and gender.
As used herein “Personal Information” means both Device Information and Order Information, but not demographic information, which remains anonymous.
We do not collect any Personal Information about you unless you voluntarily provide it to us. You may be required to provide certain personal information to us when you elect to use certain parts of the Services. These may include: (a) registering for an account with us for the Services; (b) participating in or attending live or virtual classes or events; (c) signing up for special offers; (d) sending us an email message; and (e) submitting Order Information when ordering and purchasing the Services. We also may gather additional personal or non-personal information in the future.
You are responsible for any third-party Personal Information obtained, published, or shared through the Services and confirm that you have the third party’s consent to provide the Personal Information to CTI.
How Do We Use Your Information?
CTI collects and uses your Personal Information to:
- operate its website(s) and deliver the Services;
- improve the Services;
- inform you of other products or services available from CTI and its affiliates and strategic allies;
- fulfill any orders placed by you (including processing your payment information, arranging for shipping, and providing you with invoices or order confirmations);
- communicate with you regarding Services you have requested from us;
- screen incoming orders for potential risk or fraud;
- tailor content, advertising, and email marketing to you;
- comply with legal obligations, respond to enforcement requests, and protect our rights and interests in the event of claims or disputes;
- collect aggregate statistics about use of the Services;
- understand and analyze how you use the Services and what products and services are most relevant to you; and
- evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CTI’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Under these circumstances, your Personal Information will be transferred to and used by the acquiring entity, though we will take reasonable steps to ensure that your preferences are followed.
We will not collect, use, or share additional categories of Personal Information for materially different, unrelated, or incompatible purposes other than as described above without providing you notice.
How and Why Does the Services Share Information with Third Parties?
CTI does not sell, rent, or lease its customer lists to third parties. CTI may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your Personal Information is not transferred to the third party. CTI may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to CTI, and they are required to maintain the confidentiality of your information.
We may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on CTI; (b) protect and defend the rights or property of CTI; and (c) act under exigent circumstances to protect the personal safety of users of the Services or the public.
We share your Personal Information with the following third parties:
- Google Ads
- LinkedIn Ads
- Instagram Ads
- Email Marketing
- Bing Ads
How Does CTI Process Your Personal Information?
- Legal basis for processing your information: We are committed to minimizing the information we collect and limiting its use and purposes to only: (i) where we have your permission; (ii) as necessary to deliver the Services; or (iii) as might be required or permitted for legal compliance or other lawful purpose. You may withdraw your consent to receiving our communications by clicking the unsubscribe link on any email you no longer wish to receive or by emailing us at email@example.com
- Retention of your Personal Information: Your Personal Information will be processed and stored for as long as required to complete the purpose for which it has been collected, such as providing you Services. Personal Information collected for CTI’s legitimate business interests will be retained as long as needed to fulfill such purposes. Once the applicable retention period expires, your Personal Information will be deleted from our database. Following the deletion of your Personal Information, your right to access, delete, and correct the Personal Information, as well as your right to data portability cannot be enforced.
What Are Your Rights Under the GDPR?
Under the General Data Protection Regulation (“GDPR”), CTI is a data controller and data processor for the information we collect from you. If you are a European Union resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us using the contact information below.
Additionally, if you are a European Union resident, note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Services), or otherwise to pursue our legitimate business interests. Additionally, please note that your information will be transferred outside of Europe, including to the United States.
Note that you have specific rights under the GDPR, as follows:
- You may withdraw your previously provided consent to the processing of your Personal Information at any time.
- You may object to the processing of your Personal Information if it is being carried out for a purpose for which you have previously provided consent.
- You may access your specific Personal Information in the possession of the Services, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information subject to processing.
- You may seek to have your Personal Information updated or corrected.
- Under certain circumstances, you may restrict the processing of your Personal Information, in which case we will refrain from any processing activity other than storage.
- You may seek to have your Personal Information deleted. We will honor your request to the extent that retention of your Personal Information is no longer necessary for the Services to fulfill its legitimate business purposes or legal or contractual record-keeping requirements.
- You may receive a copy of your Personal Information in a structured, commonly-used machine readable format that may be transferred to another controller without hindrance.
What is your right to access specific information?
You have the right to request that the Services discloses certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm a verifiable request from you, we will disclose to you:
- the categories of personal information we collected about you;
- the categories of sources for the personal information we collected about you;
- our business or commercial purpose for selling that personal information;
- the categories of third parties with whom we share that personal information;
- the specific pieces of personal information we collected about you
- if we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
How Can You Exercise Your Rights?
You may request to exercise your rights to access, correction, deletion, and data portability of your Personal Information by contacting us at the contact information provided below. We will endeavor to respond to your request as promptly as possible but in any event in no more than 30 days from the receipt of your verifiable request.
Only you may request to exercise your rights or those of your minor child, and your request must be verifiable. Your verifiable consumer request must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- describe your request will sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request and for no other reason. Though you need not create an account to make a verifiable consumer request, we consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account. If you have an account with us, we will deliver our written response to your account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
For requests to transfer your Personal Information to another entity, we will provide your Personal Information in a format of our choosing that is readily useable and should allow you to transmit the information without hindrance, for example in .PDF, .TXT, or .DOC format. Any disclosures we provide will only cover the 12 month period preceding our receipt of your verifiable consumer request. If applicable, our response will provide the reasons we cannot comply with your request.
We will not charge you a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide a cost estimate before completing your request.
We will not discriminate against you for exercising your rights.
We will not discriminate against you for exercising any of your privacy rights. Unless permitted under applicable laws, solely due to the exercise of your rights hereunder, we will not:
- deny you goods or services;
- charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Tracking User Behavior
As mentioned above, the Services may keep track of the websites and pages our users visit within the Services, in order to determine what Services are the most popular. This data is used to deliver customized content and advertising within the Services to customers whose behavior indicates that they are interested in a particular subject area.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/ .
Do Not Track
There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.
Security of Your Personal Information
The Services secures your personal information from unauthorized access, use, or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through the Services cannot be guaranteed.
Third Party Websites
You will be able to connect your Services account to third-party accounts. BY CONNECTING YOUR ACCOUNT TO YOUR THIRD-PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO OTHERS (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONAL INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE THIS FEATURE.
From time to time, the Services may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from the Services or click on a link therein.
If you would like to stop receiving marketing or promotional communications via email from the Services, you may opt-out of such communications by Customers may unsubscribe from emails by clicking on the UNSUBSCRIBE button.