WEBSITE PRIVACY POLICY
Last Revised: January 21, 2022
- INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://corneliascoaching.com.
By providing us with your data, you warrant to us that you are over 18 years of age. Due to the age restrictions of this website, none of the information obtained by this website falls within the Child Online Privacy Act (COPPA) and we do not knowingly intend to collect personally identifiable information from children under 18 years of age. If your minor child has provided us with personally identifiable information, you may contact us at the phone number or mailing address listed in the section entitled "Contacting Us" if you want this information deleted from our records. We will then make reasonable efforts to remove your child's information from the database that stores the information.Your Thriving & Wealthy Living / Cornelia Constantinescu is the data controller and we are 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: Thriving & Wealthy Living
Attn: Cornelia Constantinescu
Email address: thrive @ corneliascoaching.com
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 thrive @ corneliascoaching.com. - WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymized data.We may process the following categories of personal data about you:- Communication Data that 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 Data that 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 Data that 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 Data that 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 Data that 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 give-aways, 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 Data to 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 offences.We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
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 thrive @ corneliascoaching.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.
We may process your personal data without your knowledge or consent where this is required or permitted by law.We do not carry out automated decision making or any type of automated profiling.
A. Personally Identifiable InformationVoluntary submissions of personally identifiable information can occur for various reasons, such as if you request to receive information about our services, or if you subscribe to one of our mailing lists. If you subscribe to one of our mailing lists, we generally collect your name, email address, and optionally your telephone or other information if you provide it to us so we can customize your experience and better serve your needs.
In order to serve our customers, we collect personally identifiable information, like names, addresses, phone numbers, email addresses, and sometimes credit card information when such information is voluntarily submitted by our visitors. Most of your customer information is stored in a third-party Customer Relationship Manager (CRM) system, and not directly on our servers.
We will only use your personal information for the following purposes: (1) to deliver the products and/or services to you that you have requested; (2) to validate your compliance with the terms and conditions; (3) for content improvement and feedback purposes; (4) to reach you, when necessary, regarding your use of the web site or product(s), and (5) for the few situations described below to better serve you.
We will NEVER share your personally identifiable information with third parties unless you have given us explicit permission to do so, such as in order to fulfill a third party offer that you have accepted from us. By permitting us to collect this information, you will be able to receive information on other products and services that may be of interest to you, including related third party offers that we may send to you. You also enable us to personalize your experience with us so that we can provide you with the highest quality of service. We may also use this information to contact you about joint venture opportunities if it appears that you would be a suitable joint venture partner.
By submitting your email address on this web site, you agree to receive email from us. You can cancel your participation in any of these email lists at any time by clicking the opt-out link or other unsubscribe option that is included in the respective email. You can customize your email and other preferences (such as the lists you are subscribed to) by following the instructions contained in the Section entitled "Updating, Removing, Or Exporting Your Personal Information". We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do.
By submitting your email address, you also agree to allow us to use your email address for custom audience targeting on sites like Facebook, where we display custom advertising to specific people who have opted-in to receive communications from us.
If you wish to stop seeing ads from us on Facebook, you can turn off the ad by using the following steps:
1. From within Facebook, go to the advertisement you want to turn off. 2. Click on the drop-down arrow in the top corner of the ad (that may be in the top right corner or top left corner)
3. Click on "Hide ad".
You can also customize the ads you see in Facebook across all advertisers by using the following steps:- Log in to your Facebook account and click "settings".
- Click on "Ads".
- On that page you will see a list of options you can choose to limit and/or block the information Facebook shows to advertisers.
If you wish to stop seeing ads from us in Google Ads, you can turn off the ad by using the following steps: - Go to the advertisement you want to turn off.
- Click on the x in the top left corner.
- Click on "Stop seeing this ad".
Other ad platforms we may use in the future have similar ways you can turn off any ad from us to stop seeing it.
In addition, you agree that by submitting your telephone contact information on this Website and/or registering to receive the product and/or service offered herein, such act constitutes a purchase, an inquiry, and/or an application for the purposes of the United States’ Amended Telemarketing Sales Rule (ATSR), 16 CFR '310 et seq., the Telecommunications Act (Canada), and any applicable federal, national, state, provincial and local "do not call" regulations, and as such any subsequent telemarketing communications between you and us are considered exempt telecommunications. We and the specific third-party service providers receiving your data as described herein retain the right to contact you via telemarketing in accordance with the United States ATSR or the Canadian Unsolicited Telecommunications Rules and any other applicable regulations.
B. Non-Personally Identifiable InformationWe also may collect various types of non-personally identifiable information to help us make your experience more enjoyable, measure site activity to identify future improvements that should be made, and compile aggregate data to help serve site visitors better. For example, we may use such data to tailor our advertisements, develop proper survey questions, improve our business, etc.
As another example, we may use session and persistent "cookies," session logs, web beacons, GIF/pixel tags, banner ads, third-party click tracking analytics tools (such as Google Analytics), third party retargeting networks that may display our advertisements to you on other sites that you visit to remind you about us, and third party networks that serve user-requested emails (e.g., for a refer-a-friend email) to collect non-personally identifiable or other aggregated information about site visitors.
Cookies are text files that are used by your computer’s web browser to store your preferences, and enable us to enhance your user experience with our web site. Third party retargeting networks may also use cookies to display our advertisements to you on other sites. You can learn more about opting-out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.
Please note that you do have the option to configure most web browsers to NOT accept cookies. However, be aware that disabling cookies may keep you from having access to some functions or services on our web site or the web-hosted software that runs on our web site.
Emails or newsletters that we send electronically may use techniques such as web beacons or pixel tags to gather email metrics and information to improve the reader’s experience, such as the number of emails that are opened, whether they were forwarded or printed, the type of device from which they were opened, and the location (e.g. city, state, and county) associated with the applicable IP address.
If you visit this web site with an open ID (such as Facebook), you may also be sharing and integrating data with third-party social media sites, and we may track aggregate data about the number of visits to this web site with an open ID, the number of items "liked" on this web site, or items on this web site that you choose to share with a third-party social media site.
Other parties such as advertising partners and analytics companies may also be collecting information about your online activity across various websites over time. The information collected by those third parties may include identifiers that allow those third parties to tailor the ads that they serve to your computer or other device.
Because there is not yet a common understanding of how to interpret web browser-based "Do Not Track" (DNT) signals other than cookies, we do not currently respond to "Do Not Track" signals that are undefined.
Please note that you do have the option to configure most web browsers to NOT accept cookies. However, be aware that disabling cookies may keep you from having access to some functions or services on our web site or the web-hosted software that runs on our web site.
- MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests.
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 logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences] OR [by following the opt-out links on any marketing message sent to you or] OR by emailing us at thrive @ corneliascoaching.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. - 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.
- 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 will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, 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; or
- Because 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.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 fulfil 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.If you wish to exercise any of the rights set out above, please email us at thrive @ corneliascoaching.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 located in the EEA and not happy with any aspect of how we collect and use your data, we would 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
We may use session and persistent "cookies," session logs, web beacons, GIF/pixel tags, banner ads, third-party click tracking analytics tools (such as Google Analytics), third party retargeting networks that may display our advertisements to you on other sites that you visit to remind you about us, and third party networks that serve user-requested emails (e.g., for a refer-a-friend email) to collect non-personally identifiable or other aggregated information about site visitors.ces 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.
Cookies are text files that are used by your computer's web browser to store your preferences, and enable us to enhance your user experience with our web site. Third party retargeting networks may also use cookies to display our advertisements to you on other sites. You can opt-out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.
Emails or newsletters that we send electronically may use techniques such as web beacons or pixel tags to gather email metrics and information to improve the reader's experience, such as the number of emails that are opened, whether they were forwarded or printed, the type of device from which they were opened, and the location (e.g. city, state, and county) associated with the applicable IP address.
If you visit this site with an open ID (such as Facebook), you may also be sharing and integrating data with third-party social media sites, and we may track aggregate data about the number of visits to this site with an open ID, the number of items "liked" on this site, or items on this site that you choose to share with a third-party social media site.
Other parties such as advertising partners and analytics companies may also be collecting information about your online activity across various websites over time. The information collected by those third parties may include identifiers that allow those third parties to tailor the ads that they serve to your computer or other device.
Because there is not yet a common understanding of how to interpret web browser-based "Do Not Track" signals other than cookies, we do not currently respond to "Do Not Track" signals that are undefined.
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 do not accept requests via the telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.