We use the information we collect, both on its own and combined with any other information we collect about you, for the following business and commercial purposes:

• To provide the requested Services to you;
  
  
• To provide you with useful content;
  
  
• To ensure the proper functioning of our Services
  
  
• To offer and improve our Services;
  
  
• To provide you with requested information or technical support
  
  
• To facilitate your movement through our websites or your use of our Services;
  
  
• To do a better job of advertising and marketing our Services (subject to your consent where required by applicable law);
  
  
• To advertise and market third party products and services (subject to your consent where required by applicable law)
  
  
• To diagnose problems with our servers or our Services;
  
  
• In connection with our security and compliance programs;
  
  
• To administer our websites;
  
  
• To communicate with you;
  
  
• To target current or prospective customers with our products or services through online advertisements served on third-party sites by third-party vendors, such as Google (subject to your consent where required by applicable law);
  
  
• To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
  
  
• As otherwise described in this privacy notice.
  
  

We also use the information we receive to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our websites or evaluated or purchased our products or services.

Payment information that you provide to us, including credit card data, will only be used to facilitate payment for the Services.

We also use recorded telephone conversations for quality control purposes, to train our employees and for our own protection.

SHARING OF INFORMATION

As further described below, we will only share certain personal information with:

• Our partners;
  
  
• Third party service providers and vendors;
  
  
• In connection with a sale, merger, acquisition or corporate reorganization;
  
  
• Authorized users within your organization; and
  
  
• For legal reasons.

SHARING WITH PARTNERS

When we share your personal information with certain third-party partners, including marketing and advertising partners, that information includes your name, email address and other information enabling partners to:

• Assist you in using our Services,
  
  
• Contact you with offers, services or products that may be of interest to you, and
  
  
• Provide you with their products or services.
  
  

Our partners may use cookies, web beacons, pixels, tags, scripts and similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here, or if you are located in the European Union, click here. Click here to opt out of interest-based advertising on your mobile device(s). Please note you will continue to receive generic ads. Click here to access our Cookie Notice.

If you are located in a jurisdiction where such sharing requires your permission, we will only do so with your consent. Please note that if you access our services through a tool that hides your location, such as through a virtual private network, you may not receive our request for permission because we were not able to identify you as being located in a jurisdiction where your permission is required.

Further, our partners are prohibited from using your contact information for any purpose beyond those set forth above without your consent. We will not provide our partners with your credit card information.

In the event we collect information from you in connection with an offer that is jointly presented by us and a partner, we will let you know who is collecting the information and whose privacy notice applies, as well as any options you may have regarding use of your information.

SHARING WITH THIRD PARTY SERVICE PROVIDERS AND VENDORS

Occasionally, we enter into contracts with carefully selected third parties to assist us in servicing you (for example, providing you with customer service, fraud detection and deterrence or access to advertising assets and providing us with information technology and storage services) or to assist us in our own marketing and advertising activities (including providing us with analytic information and search engine optimization services). Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.

If you purchase a product or service from a third party through one of our brands, we will pass your personal information to such third party in order for them to fulfill your order.

We offer features that allow you to better target who you contact through our products and services. These features allow you to optimize your campaigns, segment your lists, and better customize your offerings to your customers. In order to do this, we partner with third parties who can provide you with information about your contacts. If both you and your contacts are located outside of the European Union, this may include demographic information and geographic location. We require that these third parties are contractually or legally permitted to share this information with you.

In order to provide you with these features, we may send third parties certain pseudonymized personal data about your contacts. These third parties are prohibited from using this personal data for any purpose beyond that for which it was shared.

We also share non-personal information with certain third parties, including the media, industry observers, marketing and advertising partners, vendors, customers, potential customers or partners. For example, we disclose mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our websites or evaluated or purchased our products and services.

Our third party service providers and vendors may use cookies, web beacons, pixels, tags, scripts and similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here, or if you are located in the European Union, click here. Click here to opt out of interest-based advertising on your mobile device(s). Please note you will continue to receive generic ads. Click here to access our Cookie Notice.

CORPORATE REORGANIZATIONS

If we are involved in a merger, acquisition, a sale of all or a substantial portion of our assets, or other similar sale transaction, your information will be transferred as part of that transaction. We will notify you by email and/or a prominent notice on our website of any such transfer and any choices you may have regarding your information.

AUTHORIZED USERS

All users authorized by you to have access to your account can view personal information stored in the account. A primary account holder can view personal information saved in subaccounts to which they have authorized access. We share information about authorized users only for legitimate purposes consistent with this privacy notice, including servicing your account and marketing products and services to you.

LEGAL PROCESS

If legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to courts of law, public authorities (including to meet national security or law enforcement requirements), and other relevant third parties, such as internet service providers, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, to bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be:

• Violating our terms and conditions of use;
  
  
• Causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or
  
  
• Violating federal, state, local, or other applicable law.
  
  

This disclosure can include transferring your information to the U.S. and other countries outside the European Economic Area. To the extent we are legally permitted to do so, we will notify you in the event that we are required to provide your personal information to third parties in connection with a subpoena.

SECURITY

The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.

When we collect financial account information, such as credit card numbers, we protect its transmission through the use of encryption such as the Transport Layer Security (TLS) protocol.

TRACKING TECHNOLOGIES AND ONLINE ADVERTISING

We use cookies, web beacons, pixels, tags, scripts and other similar technologies in the course of our business. Information about the technologies we use, why we use them (for example, in connection with online advertising), and how you can control them can be found in our Cookie Notice.

CHOICE/OPT-OUT

MARKETING COMMUNICATIONS FROM US

EMAIL

You always have the opportunity to opt out of our marketing communications with you or change your preferences by emailing us at elena@yourinnerwisdom.net. Some communications from us are considered transactional or service communications (for example, important account notifications and billing information). You agree to receive these transactional and service communications as a condition of the Services that we provide to you. You must cancel your accounts for all Services, if you do not wish to receive any transactional or service communications from us. To cancel your account, please follow the instructions found in the terms of service for the applicable Service. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.

PHONE

If you do not want to receive marketing calls by phone, you may contact customer support at the brand from which you purchased your Services and indicate your preference to us. Contact information for specific brands can be found on the homepage of each brand.

Note that we may use automated dialing technology to place marketing calls. In the event we do use such technology for marketing calls, we will do so with your consent as required to comply with applicable law. You do not need to agree to receive automated marketing phone calls or texts from us in order to use the Services.

COOKIES

For information about how to manage and opt out from cookies, please visit our Cookie Notice.

INFORMATION FROM THIRD PARTIES

To manage the information we receive about you from a social networking site or other third party (if applicable), you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this privacy notice and the information the third party collects is subject to such third party's privacy practices. Privacy choices you have made on any third party site will not apply to our use of the information we have collected directly through our Services.

UNAUTHORIZED ACCOUNTS

If an account or profile was created without your knowledge or authorization, please contact customer support at the brand on which the account or profile is located to request removal of the account or profile.

RETENTION OF PERSONAL INFORMATION

We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than seven years following the later of (i) the date on which you terminate your use of the Services or (ii) September 1, 2020, unless we are otherwise required by law or regulation to retain your personal information for longer.

LEGAL BASIS FOR PROCESSING YOUR INFORMATION

Depending on what information we collect from you and how we collect it, we rely on various grounds for processing your information under the GDPR, including the following:

• In order to administer our contractual relationship, including setting up your requested Services, payments, renewals and processes;
  
  
• Because it is in our legitimate interest to run a successful and efficient business and provide you with the Services and other useful content;
  
  
• In order to fulfill any legal obligations we may have to collect this information from you; and/or
  
  
• Because you have provided your consent for us to do so.
  
  

YOUR RIGHT TO CONTROL HOW YOUR PERSONAL INFORMATION IS USED

You have the right to make requests regarding your personal information. You can:

• Ask us to update or correct personal information if it is inaccurate;
  
  
• Request that we transfer some or all of your personal information to you or a third party (whenever it is technically feasible to do so);
  
  
• Make choices about receiving marketing communications;
  
  
• Withdraw your consent to process your personal information in circumstances where we are relying on your consent as our basis for processing.
  
  

To exercise any of your rights, please send an email to elena@yourinnerwisdom.net.

Users located in Brazil, the European Union and California have additional rights.

In addition to the rights above, Users located in Brazil, residents of the European Union and California have further rights which are detailed below. Please note that some rights only apply in certain circumstances or to certain information and some exceptions may apply.

We will require you to verify your identity before responding to any requests to exercise your rights.

RESIDENTS OF THE EUROPEAN UNION

In addition to the rights outlined above, where the GDPR or related data protection laws apply, you may:

• Ask whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
  
  
• Request that we delete the personal information we hold about you in certain limited circumstances.
  
  
• Request that we stop processing the personal information we hold about you.
  
  
• Object to our processing of data about you.
  
  

RESIDENTS OF CALIFORNIA

In addition to the rights outlined above, where the California Consumer Privacy Act 2018 ("CCPA") or related data protection laws apply, you may:

• Request to know the categories of personal information we collect about you, as well as the sources from which the personal information is collected; the business or commercial purpose of our collection; the categories of third parties with whom we share your personal information; and the specific pieces of personal information we hold about you.
  
  
• Request certain information regarding, and/or opt-out of, our disclosure of your personal information to third parties.
  
  
• Request that we delete the personal information we hold about you in certain limited circumstances.

USERS LOCATED IN BRAZIL

In addition to the rights outlined above, where the Lei Geral de Proteção de Dados ("LGPD") applies, you may:

• Ask that we provide confirmation of the existence of the processing of your personal data;
  
  
• Access the personal data we hold about you and certain information about how we use it and who we share it with including information about any public and private entities we have shared your personal data with;
  
  
• Request the deletion of personal information we have collected from you, subject to certain exceptions;
  
  
• Ask us to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD; and
  
  
• Ask us to provide information about the possibility of denying consent for the processing of your personal data and the consequences of such denial.

THIRD PARTY LINKS AND INFORMATION COLLECTION AND USE BY OUR USERS

Some of our Services provide links to other websites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information.

You may also log in to some of our Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you with the option to share certain personal information with us, such as your name and email address to pre-populate our sign up form. For example, if you take advantage of certain of our social media features, such as the Facebook Like button, and widgets, such as the "Share This" button or interactive mini-programs that run on our site, the applicable social networking sites may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable it to function properly.

CHILDREN

Our Services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian of such a child and become aware that your child has provided personal information to us, please contact us as described in this Privacy Notice and we will take reasonable steps immediately to remove any such information.

DATA TRANSFER

In order for us to provide the Services to you, your personal information will be transferred to, and stored at/processed in the United States. Your personal data may be also processed by staff operating outside the European Economic Area (EEA), such as in India and the Philippines, who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this notice.

For transfers of personal information within the Your Inner Wisdom family, such transfer will be under the Commission's model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU.

For transfers of data to third parties, such transfers will either (i) be under the Commission's model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU; or (ii) rely on the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework.

Your Inner Wisdom participates in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (together, the "Frameworks"). We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce at https://www.privacyshield.gov/list

Your Inner Wisdom is responsible for the processing of personal data we receive, under each Privacy Shield Framework, and subsequently transfer to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Your Inner Wisdom is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

You can contact us at elena@yourinnerwisdom.net to obtain a copy of the data transfer agreement or more information regarding the relevant safeguard we put in place. For more information about the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, please visit the U.S. Department of Commerce's Privacy Shield website.

NOTIFICATION OF CHANGES

We reserve the right to modify this privacy notice at any time, so please review it frequently. If we decide to change this privacy notice in any material way, we will notify you here, by email, or by means of a notice on www.yourinnerwisdom.net to the change becoming effective. In all cases, your continued use of any Services constitutes acceptance to any such changes.

COMPLAINTS

If you have any questions about this privacy notice or our data handling practices, or you wish to make a complaint, you may contact us at elena@yourinnerwisdom.net.

Last modified September 1, 2020