Effective Date: November, 2017
How We Collect and Use Information
We may collect and store personal or other information that you voluntarily supply to us online while using the Sites (e.g., while on the Sites or in responding via email to a feature provided on the Sites). The Sites only contacts individuals who specifically request that we do so or in the event that they have signed up to receive our messaging, attended one of our events, or have purchased one of our products. The Sites collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and e-mail address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events or purchasing our products. All of this information is provided to us by you.
We also collect and store information that is generated automatically as you navigate online through the Sites. For example, we may collect information about your computer's connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Sites. We also may use a standard feature found in browser software called a "cookie" to enhance your experience with the Sites. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Sites, cookies help us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Sites where you may have entered preference information before. The Sites also may use web beacons (single-pixel graphic files also known as "transparent GIFs") to access cookies and to count users who visit the Sites or open HTML-formatted email messages.
Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online - for example on message boards, web logs, through email, or in chat areas - that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
Be aware that we may occasionally release information about our visitors when release is appropriate to comply with law or to protect the rights, property or safety of users of the Sites or the public.
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.
We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- DoubleClick Platform integrations
- Google Analytics Demographics and Interest Reporting
By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Sites. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Sites, and match the right audience with the right advertising message.
We abide by Facebook’s Data Use Restrictions.
- Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
- We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
- We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
- We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.
Children's Privacy Statement
This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information regarding their rights under federal law with respect to such information.
- This Sites is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the Sites. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the Sites, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Sites.
- Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Sites, we also do NOT knowingly distribute such information to third parties.
- We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Sites.
- Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Sites, we do NOT condition the participation of a child under thirteen in the Sites' online activities on providing personally identifiable information.
The HIPAA Privacy Rule
The US Department of Health and Human Services provides: “The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections.”
You acknowledge that our operation of the Sites does not constitute the practice of medicine, and specifically does not create a doctor-patient relationship between you and Dr. Evan Hirsch. The information provided on the Sites is for educational purposes only. Though you may seek health coaching services via the Sites, health coaches are not “health care providers” and thus are not Covered Entities within the meaning of HIPAA.
Notwithstanding the fact that the Sites does not create a doctor-patient relationship between you and Dr. Evan Hirsch, our preservation of your personal health information shall be HIPAA compliant.
General Data Privacy Regulation (GDPR)
The GDPR takes effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.
As a company that markets its Sites, content, products and/or services online we do not specifically target our marketing to the EU or conduct business in or to the EU in any meaningful way. If the data that you provide to us in the course of your use of our Sites, content, products and/or services is governed by GDPR, we will abide by the relevant portions of the Regulation.
If you are a resident of the European Economic Area (EEA), or are accessing this Sites from within the EEA, you may have the right to request: access to, correction of, deletion of; portability of; and restriction or objection to processing, of your personal data, from us. This includes the “right to be forgotten.”
To make any of these requests, please contact our GDPR contact at email@example.com
How do we store your information?
Your information is stored at the list server that delivers the Sites content and messaging. 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 the Sites material.
All of the messaging or emails that are sent to you by the Sites include an unsubscribe link in them. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link that can be found in every communicaiton that we send you.
Although it is highly unlikely, this policy may be changed at any time at our discretion. If we should update this policy, we will post the updates to this page on our Website.