TheFoundationBusiness.com (Step Up Institute LLC)
Version Date: July 28, 2017
COLLECTION AND USE OF INFORMATION
We may collect and use information about you in a variety of ways. Examples of the types of data we collect and use include:
Derivative Data. Like most website operators, we gather from Users of the Website information of the sort that web browsers, depending on their settings, may make available or that our servers automatically recognize when you access the Website or the Services. That information includes your Internet Protocol (IP) address, operating system and browser type, and the locations of the websites you view right before arriving at, while navigating and immediately after leaving the Website. Such information is not personally identifiable, but it still may be possible for us to determine from an IP address your Internet service provider and the geographic location of your point of connectivity, as well as other statistical usage data. We analyze such information to help us better understand how the Website is being used. By identifying patterns and trends in usage, we are able to better design the Website to improve your experiences, both in terms of content and ease of use. From time to time, we may also release this information in the aggregate, such as by publishing a report on trends in the usage of the Website.
Personal and Financial Information. At the time you register with the Website, we may collect “Personal Information” about you, which is information that, without more, can be directly associated with a specific person. Personal Information may include your name, residential or business address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests, activities, gender, age, date of birth, username, hometown and other demographic or relevant information as determined by us from time to time. You are under no obligation to provide us with Personal Information of any kind, with the caveat that your refusal to do so may prevent you from using certain features of the Website or the Services.
Email Communications. We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time. Generally, you may opt out of such emails at the time of registration or by following the unsubscribe link in the email communications, though we reserve the right to continue to send you notices about your account.
DISCLOSURES OF INFORMATION
We may disclose your Personal Information under the following circumstances:
Marketing Communications. Unless you opt-out from receiving our marketing materials, we may email you about products and services that we believe may be of interest to you, and we also may provide your email information to our Associates so that they may directly contact you about additional products and services. If you wish to opt-out of receiving marketing materials from us, you may do so by following the unsubscribe link in the email communications, or by contacting us using the contact information provided below.
Business Partners. When you make purchases or engage in promotions offered through the Website or the Services that use third parties to deliver such product or Service, we may share your Personal Information with our business partners to offer you those products, services or promotions. When you elect to make a purchase or engage in promotions offered through the Website or the Services, you authorize us to provide your email address and other Personal Information to our business partners.
Third Party Service Providers. We may share your Personal Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services for or on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to your Personal Information and/or financial information as needed to perform their functions, but are not permitted to share or use such information for any other purpose.
Other Third Parties. We may share your aggregated information with advertisers and investors for the purpose of conducting general business analysis.
Web Beacons. We may use web beacons on the Website and in emails to count users who have visited particular pages and viewed emails, and to deliver co-branded services. Web beacons are also a technique we may use to compile aggregated statistics about usage of the Website. Web beacons collect only a limited set of information, including a cookie number, time and date of a page or email view and a description of the page or email on which the web beacon resides. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.
Analytics. We may also partner with selected third party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Website through the use of first party cookies (such as the Google Analytics cookie) and third party cookies (such as the DoubleClick cookie), including Google Analytics for Display Advertising and Google AdWords. If you do not want any information to be collected and used by Google Analytics, you can install a Google Analytics opt-out plugin in your web browser, update your preferences in the Google Ads Settings page or use the Network Advertising Initiative opt-out tool.
LINKS TO THIRD PARTY WEBSITES
We use reasonable administrative, technical and physical measures to protect your Personal Information from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. Any data disclosed online is vulnerable to interception and misuse by unauthorized third parties. We cannot guarantee that only authorized persons will view your Personal Information. We are not responsible for third party circumvention of any privacy settings or security measures.
CHANGING OR TERMINATING YOUR ACCOUNT
POLICY FOR CHILDREN
The Children’s Online Privacy Protection Act protects the online privacy of children under 13 years of age. The Website and the Services are not directed to children, and we do not knowingly collect or maintain Personal Information from anyone under the age of 13. If we learn that Personal Information has been collected from a user under 13 years of age, we will take the appropriate steps to cause this Personal Information to be deleted from our records. If you are the parent or legal guardian of a child under 13 years of age who has registered with the Website or has otherwise transferred Personal Information to the Website, please contact us using the contact information provided below to have your child’s account terminated and Personal Information deleted. If you are under 18 years of age, reside in California and have a registered account on the Website, you have the right to request removal of unwanted Personal Information that you publicly disclose on the Website. To request removal of such Personal Information, contact us using the contact information provided below and include a statement that you reside in California. While we will make sure the Personal Information is not publicly displayed on the Website, please be aware that the data may not be completely or comprehensively removed from our systems.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared, and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
Attn: Privacy Officer