Thank you for visiting our website, https://www.alisacohn.com, (“Site”). Alisa Cohn & Associates, Inc. (“Company”) is committed to treating the personal and corporate information of our Site users, customers, and vendors with respect and sensitivity.
If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any CCPA-specific information is identified in this Policy.
Region specific provisions. Certain provisions of this Policy, which are clearly labelled, apply only to users who are citizens or residents of particular regions (e.g., the EU or California). Otherwise, the Policy applies to all users of our Services, regardless of location.
Children. The Services of the Company are not directed to children. If you become aware that a child (based on the jurisdiction where the child lives, which in the United States means someone under the age of 13) has provided us with Personal data without parental consent, contact us at firstname.lastname@example.org.
2.WHAT PERSONAL INFORMATION DOES THE COMPANY COLLECT?
We collect personal information that you enter on our Site or otherwise volunteer to us when you contact us to, among other things, make purchases, request information, or register for or attend our programs. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features.
For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal Information comprises the categories of Personal Information defined by the CCPA, which includes:
Name, address, email, phone, SSN, driver’s license
Financial information, medical information, health insurance information
Race, gender, sexual orientation, religion
Records of personal property, purchasing or consuming histories
Fingerprints, retina scans, face prints
Browsing history, search history, IP address, website interactions
GPS coordinates, location history
Audio, electronic, visual, thermal, olfactory
CV, resume, employment history
Educational background, grades, scores
Drawn the above categories, such as preferences, characteristics,
attitudes, predispositions, abilities, aptitudes,
intelligence, psychological traits
The examples given in this table are not meant to provide an exhaustive list but are examples of the kinds of data included in each category. Company does not collect Personal Information in every one of these categories, and we identify below which categories we collect.
Personal Information under the CCPA also includes any other category of personal information not included within the CCPA’s definition that are defined in California Civil Code § 1798.80(e). We refer to this category as “Other Data,” and it includes information such as financial information (bank account number, credit card number, debit card number), medical information, health insurance information, and insurance policy number.
Our Company collects only that Personal Information that is relevant for the purposes for which the data is requested. The Company does not use your Personal Information in any way that is incompatible with the purposes for which it was collected or for which you have consented.
INFORMATION YOU GIVE US
When you contact us through our Site, or by corresponding with us by phone, e-mail, or otherwise, or attend a Company event, we may collect Personal Information including:
- Identifiers: Name and Email Address
- We do not collect or receive Biometric Information or Sensory Data.
INFORMATION WE COLLECT AUTOMATICALLY
- Internet Activity: When you visit our Site, our web server automatically collects and stores the following information:
- The Internet protocol (IP) address used to connect your computer to the Internet, referring website address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages on our Site you viewed; page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number;
INFORMATION WE RECEIVE FROM OTHER SOURCES
This is information we receive about you from third parties who operate other Sites or services we use in order to provide our products and services to you. We work closely with third parties, including, for example, business partners, promoters, affiliates, and sub-contractors in technical, payment and delivery services, advertising networks, marketing analytics providers, promotions, and search information providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
3. HOW DOES THE COMPANY USE PERSONAL INFORMATION?
INFORMATION YOU GIVE US
We will use this information:
- to provide you with the Services that you request from us;
- to carry out our obligations arising from any contracts entered into between you and us, or between you and our promoters, affiliates, or distributors;
- to contact you in the future to provide you with information about other products and services we offer, or that are offered by our affiliates or third party vendors;
- to notify you about changes to our Services;
- to comply with applicable laws and regulations;
- to assess your suitability for participation in our live events, and to determine additional Company materials, services, or events to recommend and market to you;
- for training purposes, quality assurance, and to record details about the products and services you order from us;
- to make inquiries about you for credit reference purposes;
- to perform data analyses (including anonymization and aggregation of Personal Information).
INFORMATION WE COLLECT ABOUT YOU.
We will use this information:
- to provide targeted advertising and marketing services;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our site safe and secure.
INFORMATION WE RECEIVE FROM OTHER SOURCES.
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. DO WE SHARE YOUR PERSONAL INFORMATION WITH ANY THIRD PARTIES?
To provide the Services, we sometimes disclose Personal Information to service providers for business purposes. Sometimes we disclose your Personal Information to those third parties, and they sometimes collect your Personal Information in the first instance and provide it to us.
Our service providers are contractually obligated to comply with all applicable laws (e.g., the CCPA), and all such third parties use your Personal Information only on behalf of Company and under the instructions of Company on how your information may be used and processed. Company takes reasonable steps to ensure these third parties use your Personal Information only for the purposes for which they have been engaged by Company, that they do not share or sell your Personal Information to anyone else.
By enjoying our Services and sharing your Personal Information, you agree that we have the right to share the categories of Personal Information we collect, as identified in Section 2 with our service providers for the following business purposes:
- Sales – for the purpose of fulfilling requests from you to purchase goods and services from our Site or at our events;
- Targeted advertising – to provide advertising of Company’s programs and services on other Sites and platforms;
- Marketing – for the purpose of direct marketing of goods and services offered by Company and our affiliates that you may be interested in;
- Cloud services – for provision of cloud storage services;
- Contractual performance – for the performance of any contract we enter into with you, or they enter with you on behalf of Company;
- Web analytics — analytics and search engine service providers that assist us in the improvement and optimization of our site.
We may also disclose your personal information to third parties in the following circumstances:
- In the event that we sell or buy any business or assets, in which case we will disclose your Personal Information to the prospective seller or buyer of such business or assets as part of the purchase, transfer, or sale of services or assets;
- If we sell all or substantially all of our assets to a third party, in which case personal information about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or any lawful request by public authorities (including to meet national security or law enforcement requirements), or in order to enforce or apply other agreements; or to protect the rights, property, or safety of us, our customers, or others.
Whenever we share information with third parties, we will take reasonable steps to ensure that the third parties put in place adequate measures to safeguard your Personal Information, and they will be required to use any Personal Information for only the intended purpose for which it was shared.
5. OUR STORAGE OF YOUR PERSONAL INFORMATION
Company uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect.
We will keep your personal data for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.
You may unsubscribe from any of our online e-mail updates and marketing by following the unsubscribe instructions in the body of any e-mail message we have sent to you. We will take commercially reasonable steps to implement your unsubscribe requests promptly, but you may still receive promotional information form us by mail for up to sixty (60) days, and up to ten (10) days for e-mail. You may also continue to receive information from those third parties to whom we have previously disclosed your Personal Information.
Please note that when you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
6. ACCESS TO OTHER WEBSITES
7. PROTECTING CHILDREN’S PRIVACY
8. ADDITIONAL POLICIES IN COMPLIANCE WITH THE CCPA
The CCPA affords California consumers the rights with respect to their Personal Information set forth in this section.
8.1 RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, USED, DISCLOSED, OR SOLD
California consumers have the right to request that the Company disclose what personal information it has collected, used, disclosed, and sold over the 12-month period preceding the Company’s receipt of such a request. To exercise this right, a California consumer must submit to the Company a verifiable request to know such information. This request can be submitted by following the procedures set forth in the Contact Us section, below.
8.2 RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION
California consumers have the right to request the deletion of their personal information collected or maintained by the Company. To exercise this right, a California consumer must submit to the Company a verifiable request to delete such information. This request can be submitted by following the procedures set forth in the Contact Us section, below.
8.3 RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF A CONSUMER’S PRIVACY RIGHTS
California consumers have the right to not be discriminated against because the consumer exercised any of the consumer’s rights under the CCPA. That means that the company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA ((unless the different rate or different level or quality is reasonably related to the value to the business of the consumer’s data).
8.4 SUBMITTING A CCPA DATA REQUEST
To submit a request to know about the Personal Information we collect about you as described in Section 8.1 or a request for deletion of your Personal Information as described in 8.2, please contact us by emailing us at email@example.com.
Company is required to verify the identity of the individual requesting access to a consumer’s data or requesting deletion of a consumer’s data. To verify your identity, you must provide: your name and email address.
· if Company has previously received your email address, Company may verify that you have access to that email address by sending a verification code; or
· if Company has previously received your mobile number, Company may text you a verification code.
8.5 AUTHORIZED AGENT
California consumers may designate an authorized agent to exercise a CCPA right on the consumer’s behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer’s behalf will need to be provided:
· Proof of written permission by the consumer for the authorized agent to act on his or her behalf and separate verification of the consumer; or
· Proof that the authorized agent holds a power of attorney to act on the consumer’s behalf pursuant to Cal. Probate Code §§ 4000-4465.
9. ADDITIONAL POLICIES IN COMPLIANCE WITH THE EEA PRIVACY LAWS
9.1 GDPR DEFINITIONS
“Controller” means the Company which is the organization that determines the purposes for which, and the manner in which, any Personal Information is Processed and used in its business.
“Processor” means any Person Processing Personal Information.
“Person” means a natural person, corporation, association, organization, partnership, or other legal entity.
“Processing” is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording, or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring Personal Information to third parties.
9.2 THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
In order to comply with the GDPR, we are required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for processing your Personal Information will typically be one of the following:
- our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors, such as, for example, providing direct marketing to our customers of our products and services that we think would be of interest, permitting prospective employees to search and apply for job opportunities, handling inquiries from our promoters, affiliates, distributors, vendors, and customers, or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest;
- the performance of a contract that we have in place with you;
- your consent where appropriate; or
- compliance with our legal obligations, including to meet national security or law enforcement requirements.
9.3 WHERE WE STORE YOUR PERSONAL INFORMATION
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
9.4 ADDENDUM TO HOW LONG WE STORE YOUR PERSONAL INFORMATION
In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Except in those circumstances, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.
9.5 YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION
Subject to certain exceptions, you have the following rights with respect to your Personal Information:
- To receive or access a copy of the Personal Information that we hold about you;
- To request that any inaccurate or incomplete Personal Information be corrected or supplemented;
- To have your Personal Information erased, unless we have a legitimate reason to retain the Personal Information (such as if we are required to do so for legal reasons); and
- To ask us not to process your Personal Information for a particular purpose, including for marketing.
All of these rights are subject to certain conditions and exemptions. For example, Company will not be obligated to erase your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.
To exercise any of these rights, please submit a written request to us using the contact information set forth below. The Company reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.
11. CONTACTING US