This policy was last updated on May 24, 2018 (to incorporate GDPR Privacy and Data Protection law)
This privacy notice applies to any Reece International LLC (DBA Training for Optimal Performance) website, application, service, or tool (collectively “Services”) where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices.
4. Information We Collect
We may collect both “Non-Personal Information” and “Personal Information” about you.
“Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.
“Personal Information” is information relating to an identified or identifiable natural person and includes information that can be used to personally identify you, such as your name, address and email address.
An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
We collect personal information from you when you use our Services. The data we collect consists of:
- Data that you provide directly when you register for, or use, the Services. This data will vary, but typically consists of name, email address, postal address, phone number, and other similar contact data. We also receive data from the communications you send to us, such as customer service inquiries, forms, surveys, social media community interactions, discussion groups, webinars, program questions, and other feedback regarding the Services.
- User credentials, such as username, password, password hints and similar security information used to create an account and authenticate users of the Services.
- Demographic data, such as age, gender, country, and language preference.
- Payment data, such as credit card information and billing address.
- Device data, such as type of device, operating system, and other software installed on the device, device settings, IP address, device identifiers and error reports.
- Usage data, such as the programs and features you access, items you purchase, and the timing, frequency and duration of your interactions through the Services.
- Location data, such as IP addresses received from your device.
- Information about your interests and preferences, such as which free resources you download from our websites, which emails you open, or your communications preferences. In addition to what you provide directly, we may infer your interests and preferences from other data we collect, such as the content and advertisements you interact with while using the Services.
- Third party integrations. If you connect your use of the Services through a third party service (e.g., a social media platform), the third party may share certain information from your third party account with us.
- Other third party data, such as data from our affiliates, partners, or vendors, data brokers or public sources.
In addition, we may also track information provided to us by your browser or by our mobile application when you view or use the Services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Services, the time and date of access, and other information that does not personally identify you. We use this information for, among other things, the operation of the Services, to maintain the quality of the Service, to provide general statistics regarding use of the Services and for other business purposes. We track this information using cookies, or small text files which include an anonymous unique identifier.
5. Cookies & Similar Technologies
Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal Information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. Persistent cookies can be removed by following your Internet browser help file directions. If you choose to disable cookies, some areas of the Services may not work properly.
Company websites, e-mail messages, and advertisements may use “cookies” and other technologies such as tracking, re-marketing tags, and pixels based on context, e.g., a search query, a channel you are reading, or inferred interests. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.
We treat information collected by cookies and other technologies as non-personal information. We design and target advertising based on how you interact with the Company and our Services. If You do not wish to receive ads targeted to your interests from our Company, you can choose to limit ad tracking, which will opt your Company ID out of receiving such ads regardless of what device you are using. You may still see ads based on context like a search query or a channel you are reading.
To limit ad tracking, you may opt-out by clicking on this tool (https://www.youradchoices.com/control ) for (USA) or this tool (http://www.youronlinechoices.eu/ ) for (EU) both of which are not Training for Optimal Performance affiliated. You may also use your browser’s settings to disable cookies and other tracking tools. Please note that certain features of the Company website will not be available once cookies are disabled. We gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. The Company may use this information in our marketing and advertising services.
In some cases we use a “click-through URL” linked to content on the Company website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our marketing communications. We also use it to account for Affiliate activity and pay Affiliate commissions and bonuses.
6. How We Use Your Personal Information
We use your personal information to provide and improve our Services, provide you with a personalized experience on our websites, contact you about your programs or purchases with us and our Services, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate, and investigate fraudulent or illegal activities.
We use the data we collect for the following purposes:
Operating our business. We use the data we collect to operate our business, including providing and improving the Services. Specifically:
- To fulfill transactions that you request.
- To diagnose and fix problems with the Services and providing other customer support services.
- For analytical purposes to better understand our clients and community and how they use the Services, which allows us to continually improve and expand the Services.
- To build predictive models, which allow us to tailor the Services based on the data we have about how our clients and target audience use the Services.
Communicating with you. We use the data we collect to communicate with you, including responding to your requests or inquiries. Specifically:
- To respond to your request if you contact us with a question or concern.
- To provide information about your access to our programs, your use of the Services, or other transactions that you request.
- To deliver news, updates, and other types of communications, according to your subscriptions, alerts, and other preferences.
Marketing and advertising. We use the data we collect for marketing or advertising purposes, on behalf of ourselves, as well as our sponsors and other parties. Specifically:
- To send you information content, promotional messages, and information about products, services, programs, or events that may be of interest to you. These may be offered by Training for Optimal Performance, or by our partners and other third parties with whom we have a relationship.
- The promotional messages and advertisements that you see may be determined by data that we collect or receive about you, such as your demographic data, location data, usage data, interests, and preferences. We refer to this as “interest-based advertising”.
Security, compliance and enforcement. We use the data we collect for security, compliance, and enforcement purposes. Specifically:
- To protect the safety and security of our clients and our Services.
- To detect and prevent abuse, fraud or other unlawful or unauthorized activities.
- To resolve disputes.
- To enforce our agreements, including our policies and terms of service that govern your use of the Services.
We may also use your data in any other manner as disclosed at the time of collection, or when we have otherwise obtained consent. Please also note that this Policy is not intended to place any limits on what we do with aggregated, pseudonymized, or anonymized data.
7. How We Might Share Your Personal Information
We may disclose your personal information to other members of the Reece International LLC (DBA Training for Optimal Performance) corporate family, or to third parties. We may share your Personal Information with vendors and other third-party providers who are performing services for the Company. This disclosure may be required for us to provide you access to our Services, to comply with our legal obligations, to enforce our User Agreement, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. We do not sell, rent, or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your consent.
However, certain third-party service providers, such as payment processors, have their own privacy policies in respect of the information that we are required to provide to them in order to use their services. For these third-party service providers, we recommend that you read their privacy policies so that you can understand the manner in which your Personal Information will be handled by such providers.
8. How Long We Keep Your Personal Information
We retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies.
9. How We Protect Your Personal Information
Training for Optimal Performance takes data security seriously. We take a number of steps to protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. These steps take into account the sensitivity of the data we collect and use, as well as the current state of technology.
It is important to remember that no system can be guaranteed to be 100% secure. By using our Services, you acknowledge that you understand and agree to assume these risks. We recommend that you help us keep your data safe by taking reasonable steps such as keeping your passwords private and not disclosing sensitive personal data, such as credit card information, in places that can be accessed easily (such as via email).
10. Your Rights Regarding the Use of Your Personal Information
You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided at the bottom of each promotional e-mail.
11. Your Rights Under the General Data Protection Regulation (GDPR)
If You are a citizen or a resident of a country in the European Union, the GDPR grants You the following rights:
- Access to Your Personal Data: You have the right to receive a copy of your personal data that is subject to processing by our Company. Ordinary requests will be granted without charge to you within one calendar month of when you make the request. In cases of excessive, unreasonable, or repeated requests our Company may charge you a reasonable fee and may require additional time to grant your request. Also, our Company may use reasonable means to confirm your identity before granting any request for data so as to prevent granting fraudulent requests. To request a copy of your personal data, please contact us by e-mail at firstname.lastname@example.org
- To have Your Data Corrected: If your personal data is erroneous or outdated, you have the right to have it corrected. To do so, please contact our Company via e-mail at email@example.com
- To be Forgotten: You have the right to be forgotten by our Company. You may exercise this right by e-mailing us at firstname.lastname@example.org. We will comply with your request, at no charge to you, within one calendar month by deleting your account, along with all of your personally-identifiable data that is subject to any Training for Optimal Performance processing. Naturally, after we grant your request you will not have access to any Training for Optimal Performance products or services unless and until you open a new Company account. Our Company may use reasonable means to confirm your identity before granting any request for data so as to prevent the granting of fraudulent requests.
- To Restrict Processing of Your Data: You can request that your data not be processed via Training for Optimal Performance partners. You can make that request by e-mailing us at email@example.com, if you wish, you can even specify which third parties to restrict from processing your data. We will respond to your request, at no charge to you, within thirty (30) days from when you make your request. Please be advised that some of our partners, e.g., Infusionsoft.com, are essential to our Company services, so that if you block processing by them, our Company’s services may be unavailable to you.
- Portability: You have the right to receive a copy of your personal data that is subject to processing by our Company in a portable format, or to have it transferred directly from our Company to another party. Ordinary requests will be granted without charge to you within one calendar month of when you make the request. Our Company may use reasonable means to confirm your identity before granting any request to transfer data to you or another party so as to prevent granting fraudulent requests. To request a copy of your personal data in a portable format, or to request a direct transfer of your data, please contact us by e-mail at firstname.lastname@example.org
12. Data Controller
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. Angelique Rewers Worldwide LLC (DBA The Corporate Agent) is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our privacy notice, as well as any applicable national laws.
13. Links to Other Websites
14. Age of Consent
By using the Service, you represent that you are at least 18 years of age. Children under the age of 18, are not permitted to create their own Training for Optimal Performance IDs; instead, a parent must obtain the account and provide the parent’s information to Training for Optimal Performance. If we learn that we have collected the personal information of a child under 18 we will delete the information as soon as possible.
We may change this Policy from time to time to reflect changes in our business, the Services, or our practices and procedures. If we do make changes, we will post any changes on this page and indicate the date on which the Policy was last revised. We encourage you to review this Policy periodically, especially before you provide personal data directly to us through the Services. Your continued use of the Services after any changes to this Policy are in effect constitutes your acceptance of the revised Policy.
16. Merger or Acquisition
17. How to Contact Us
8805 Tamiami Trail North
Naples, FL 34108