EDUCE, INC. PRIVACY POLICY
December 13, 2019
We at Educe, Inc. (“Educe,” “Limitless Adviser,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how the information you provide to us is used and shared. We make every effort to protect the information we collect while delivering insightful, relevant and integrated Services in ways that advance your financial and personal success.
This Privacy Policy describes our current information management practices and applies to our information collection and use practices: (i) online when you visit any of our websites, including, without limitation, limitlessadviser.com, stephaniebogan.com, lacpgroup.com, collectively the “Websites” or “Sites”), the services available through our Site (collectively, the “Services”) and (ii) offline when you provide information to us.
Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Service.
ACCEPTANCE OF TERMS
By visiting any of our Websites, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service, both of which govern your use of the Websites. Your continued use of our Websites after we make changes to this privacy policy is deemed to be acceptance of those changes, so please check the policy periodically for updates. By providing us information offline, you are also agreeing to the terms of this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy).
THE INFORMATION WE COLLECT
In the course of providing Services, operating the Websites and/or interacting with you, we will collect (and/or receive) the following types of information. We are the sole owners of the information collected on this site. We only have access to and/or collect information that you voluntarily give us via email or other direct contact from you, as well as automatically through your use of our Websites or Services. We will use your information to provide Services or to respond to you regarding the reason you contacted us.
Depending on the situation and the sensitivity of the information, you give us consent in different ways.
Consent is express when you actively say yes, such as when you sign a form permitting the collection. Implied consent is usually inferred by the use of our Services and/or Websites.
1. PERSONAL INFORMATION.
When you sign up to receive any of our newsletters, respond to a survey, register for a class, or purchase any product or service, you may be required to provide us with personal information about yourself, such as your name, address, email address, and phone number. We do not collect any personal information from Visitors when they use the Websites unless they provide such information voluntarily, such as by registering or sending us an email or signing up for a newsletter. All information we collect and/or receive under this section is collectively called “Personal Information.”
Educe only discloses potentially personally-identifying and personally-identifying information only to its employees, contractors and affiliated organizations that need to know that information in order to (i) process it on the behalf of Educe, (ii) provide Services available through Educe and our Websites, and (iii) that have agreed not to disclose it to others. We will not rent or sell potentially personally-identifying and personally-identifying information to anyone.
2. Membership INFORMATION.
Certain areas and features of our Websites and Services may require Membership registration. To register, you must provide your email address, first name, last name. We also may collect additional optional information from you, including your location, phone number, and other information entered by you at will. We use this information to provide Services and to contact the user regarding memberships, for administrative matters. and to display a membership directory for registered members of our Site.
3. ORDER INFORMATION.
When you place an Order, you must provide us with certain information about the products and services you are seeking to purchase. Such information is collectively called the “Order Information.”
4. BILLING INFORMATION.
When you wish to purchase a product or service, you will be required to provide certain information in addition to the Personal Information, Membership Information and Order Information noted above. Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information. Such information is collectively called the “Billing Information.” Although we will have access to the Billing Information, it will also be collected and processed by our third-party payment vendors pursuant to the terms and conditions of their privacy policies and terms of use.
5. OTHER INFORMATION.
In addition to the information noted above, we may collect additional information (collectively, the “Other Information”) about your use of our Site or Services through cookies, third-party analytics, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the webpage that led you to our Site, and the following: access time, browser type, domain name, IP address, page views and referring URL. Such Other Information may include:
- From You. Additional information about yourself that you voluntarily provide to us (e.g., via a survey), such as, but not limited to: business revenue, gender, product and service preferences, and other information that does not identify you personally.
- From Your Activity. Information that we automatically collect when you use the Websites, including, without limitation:
- IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Websites you visit; and similar data; and
- Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.
- From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Websites. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Websites may not function properly.
- Third-Party Analytics. We use third-party analytics services (such as Google Analytics) to evaluate your use of the Websites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Websites and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Websites, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Websites.
- From Other Sources. We also may collect or receive information from third parties, such as Facebook and/or other third-party social media sites.
ACCESSING AND MODIFYING PERSONAL INFORMATION AND COMMUNICATION PREFERENCES
If you have registered for the Websites, you may access, review, and make changes to your Personal Information, Billing Information, and certain Other Information by following the instructions found on the Websites. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Educe marketing email. Customers cannot opt out of receiving transactional emails related to their account or their Orders. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.
INFORMATION YOU SHARE
Please keep in mind that whenever you voluntarily make your Personal Information available to third parties — for example on forums, community, message boards or blog; through email; during webinars, classes, telephone conferences, or coaching calls; or in comment or chat areas — that information can be seen, collected, heard, and/or used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Your search queries on the Website.
- You also may provide information to be published or displayed (hereinafter, “Posted”) on private or public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
HOW WE USE AND SHARE THE INFORMATION
We use the Personal Information, Membership Information, Order Information, Billing Information, and Other Information (collectively, the “Information” that we gather about you for the following purposes:
- To present our Website and its contents to you and to allow you to participate in interactive features on our Website.
- To provide our Services to you and carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To communicate with you about your use of our Services, to respond to your inquiries, to fulfill your membership application, and for other customer service purposes.
- To solicit your feedback.
- To maintain and improve our Websites and services to you.
- To tailor the content and information that we may send or display to you to personalize your experiences while using the Site or our Services.
- To provide you with information, products, or services that you request from us or those of our third-party partners.
- To provide marketing and promotional opportunities. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about Services or information we think may interest you.
- Fulfill any other purpose for which you provide it.
- Notify you about changes to our Website or any products or services we offer or provide though
We may also use and/or share Information as described below.
- We may employ other companies and individuals to perform functions on our behalf. Examples may include providing coaching services, technical assistance, order fulfillment, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
- In an ongoing effort to better understand our Visitors, customers, and our products and services, we may analyze Information in aggregate form in order to operate, maintain, manage, and improve the Websites and/or our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- With your permission, third-party applications or services may access your Personal Information. We use standard OAuth (open authorization) to enable you to give permission to share your Personal Information with other websites and services, such as Facebook and Twitter (e.g., when you agree to a pop-up requesting you to allow another application to access your account information). We also use OAuth to allow us to share information about you that is stored by us without sharing your security credentials.
- We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
- As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
- To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Educe, Inc. or others.
- For any other purpose with your consent and in any other way as described when you provide the information.
HOW WE PROTECT THE INFORMATION
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not be secure, and you should therefore, take special care in deciding what information you send to us via email.
You should promptly notify us if your account, username or password have been lost or stolen. Take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. We will never ask you for your password. If you need a new username and/or password, you will generate a new password automatically through the Website, which may be sent via email.
IMPORTANT NOTICE TO NON-U.S. RESIDENTS
It is important to note that the Websites and their servers are operated in the United States. If you are located outside of the United States, please be aware that any Information you provide to us will be transferred to the United States. By using the Websites and by providing us Information when using our services, you hereby irrevocably consent to this transfer and our use of the Information and data provided by you in accordance with this Privacy Policy.
SITE INTENDED FOR USE BY ADULTS
Website is intended for use by adults and is not intended for use by minors. We do not knowingly collect personal information from minors. If you are a minor, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a minor please contact us at limitlessadviser@educeinc.com.
EXTERNAL WEBSITES
The Websites may contain links to third-party websites. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. As such, Educe, Inc. is not responsible for the privacy practices, security practices or the content of any third-party website. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. By accessing the Websites and/or using our services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.
HOW TO CONTACT US
If you have questions about this Privacy Policy, please contact us via email at limitlessadviser@educeinc.com with “Privacy Policy” in the subject line.