Last Updated: February 2020
INFORMATION THAT WE COLLECT
Website provides several opportunities for you, the user, to voluntarily provide us with your personal information in exchange for a free resource, to be added to or email or subscriber list, or to contact us. If you elect to “opt-in” and provide us with your personal information for any of these purposes, we will collect the information you provide, which may include your name, email address, phone number, and the text of any message you send us. We will also process personal information in the form of comments, images, or videos you make or share on our blogs, social media pages, or any other online forum currently available, or made available in the future. You understand that your decision to provide any information to us in this manner is voluntary, and constitutes your clear consent to allow us to collect, process, and retain it.
If you elect to fill out the “contact us” portion of our website, or provide us with any other communication data, including but not limited to that provided via email, social media messaging or posts, or text messages, we may collect information including your name, email address, phone number, information you share with that social media platform, as well as the text of any message you send electronically. This data will be processed based on our legitimate interest in communicating with you, answer any questions or concerns you have. We may also retain your data to keep a record of the communication.
If you become a customer, we will collect additional information in order to carry out and complete the purchase and sale of the goods or services you have requested, including but not limited to your name, email address, billing address, credit card or payment information, and any other information necessary in order to complete the purchase of the product or service you elect to buy. We will collect and process this data in order to fulfill our contractual obligation to complete your order and will not retain the information any longer than necessary. We use third party data processors to take and complete payment, and we will not retain nor have access to your payment information.
If you are on our email list due to your consent to be added, or our legitimate interest in engaging in direct marketing, we may also use your data to send you targeted social media advertisements or upload your information into our social media account to create look-a-like audiences. To ensure compliance with the CAN-SPAM act, all emails from us will clearly state the sender of the email, as well as provide instructions on how to unsubscribe from our list, or contact us with any questions or concerns. We will not rent or sell your email address to anyone without your express, written permission.
We may also collect information though Automatic Data Collection Technology. We may use or send standard “cookies” to identify your browser from time to time. We do not include any personally identifiable information in cookies, and will not employ any other mechanisms (other than those discussed above) to capture data on our website. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). You can accept or decline cookies using your web browser settings. If you choose to disable cookies, some areas of Website may not work properly or at all. Website does not respond to Do Not Track signals sent by your browser.
We may also collect data about how you use Website, your browsing actions or patterns, computer equipment, IP address, internet connection, and other similar choices you make, including via Google Analytics and Facebook Pixels, in order to obtain statistical data, improve our website and offerings, and ensure you receive information relevant to you. If we utilize this technology, we will use them in compliance with all policies of these third party companies. We may receive personal data from third parties including Google, social media platforms, search engines, Paypal, Stripe, and other third party payment processing companies.
Lawful Grounds for Processing: In order to ensure compliance with the European Union’s General Data Protection Regulation (“GDPR”) we confirm we have lawful grounds for processing the information we collect from you. If you provide your personal information via our “contact us” page or send us any other form of electronic communication, we will process your data based upon our legitimate interest to respond to user or customer inquiries. If you elect to receive communication from us by “opting in” and provide us with your name and email address in exchange for a free resource or training, or if you purchase from us, we will process your data for the purpose it was collected based on your affirmative consent to do so, and may periodically send you additional email marketing based upon our legitimate interest in marketing to those that have shown an interest in our products or services. We may also give you the option to be added to our email list, in order to receive our newsletter, information about our products and services, and other information we believe may be of interest to you based upon your decision to opt-in to one or more of our free resources, and will obtain your consent to do so. You may withdraw consent at any time by contacting us and requesting your information be edited, updated, or deleted. We do not collect any sensitive data, nor any information regarding criminal offenses or convictions.
On occasion, You may give Us additional data in order to enter into a contest or giveaway or to participate in a survey. You will be prompted for this information and it will be clear that You are offering this kind of information in exchange for an entry into such a contest or giveaway.
HOW AND WHY YOUR INFORMATION IS COLLECTED
We collect your personal information when you voluntarily, directly provide it to us to receive a free or paid resource, product, or service, or when you fill out a form or send an email to contact us, and we do so in order to provide you with the resource you have indicated you’d like to receive. We may also track your future interactions with our content, and use your personal information to keep you informed about the products and services you have elected to receive, as well as any linked or similar products or services we think you may be interested in. The information will be collected by us following your choice to manually enter it in, and click to be added to our list. No such information will be collected without your taking action to be added to our list, or in exchange for a free resource.
We may also receive data from third parties like Google Analytics, Facebook and other advertising platforms, providers of technical or payment services as needed, and other similar third parties. We do our best to only utilize third parties who have been deemed GDPR-compliant, and whom we have either completed a data processing agreement with, or have reviewed and confirmed their policies regarding data processing to ensure compliance.
HOW WE USE YOUR INFORMATION
You have the right to know and understand how your information is used. We will use the personally identifiable information you voluntarily give us in order to carry out the service or product you requested, including free resources, trainings, newsletters, periodic promotional emails, and to notify you about any changes to our policies or services. We may also use your personal information to form “look-a-like” audiences in our digital marketing campaigns, which includes uploading your information into our social media advertising campaign.
If you purchase something from us, we will use your billing address and credit card information to complete your desired purchase or purchases only, and will not store or share any such information. By providing this information to us, you understand and agree that we may use and store such information to send emails, bill credit cards in exchange for programs or products purchased, or utilize comments for marketing purposes.
If you make a purchase from us, we may also use your personal information to send necessary updates to our products or services you have purchased, or to keep you informed of any necessary information relating to our products or services.
Non-Personally Identifiable Information: Additional non-identifying information that is collected may be used to provide an overview of how people are accessing and using Website; it is not used for any additional purposes, and Website does not use any such data to make automated decisions. We may also record some or all information to help create a better user experience. We may use information such as your IP address to help diagnose technical problems with servers or our website, and to determine which portions of our website receive the most traffic, to understand which content is the most useful to our visitors. Your IP address will not personally identify you, and may be used in such limited purposes as outlined above, in order to improve user experience.
Your information allows Us to offer You certain products and services, including the use of Our website, to fulfill Our obligations to You, to customize Your interaction with Our company and Our website, and to allow Us to suggest other products and services We think might interest You. We generally store Your data and transmit it to a third party for processing. However, to the extent We process Your data, We do so to serve Our legitimate business interests (such as providing You with the opportunity to purchase Our goods or services and interact with Our website or mobile app).
Specifically, We may use the information and data described above to:
- Create and administer Your account; and
- Deliver any products or services purchased by You to You; and
- Correspond with You; and
- Process payments or refunds; and
- Contact You about new offerings that We think You will be interested in; and
- Interact with You via social media; and
- Send You a newsletter or other updates about Our company or website; and
- Deliver targeted advertising; and
- Request feedback from You; and
- Notify You of updates to Our product and service offerings; and
- Resolve disputes and troubleshoot any problems; and
- Administer contests or giveaways; and
- Generate a profile that is personalized to You, so that future interactions with Our website will be more personal; and
- Compile anonymous statistical data for Our own use or for a third party’s use; and
- Assist law enforcement as necessary; and
- Prevent fraudulent activity on Our website or mobile app; and
- Analyze trends to improve Our website and offerings.
GROUNDS FOR USING AND PROCESSING YOUR DATA
The information We collect and store is used primarily to allow Us to offer goods and services for sale. In addition, Monique Sar International may collect, use, and process Your information based on the following grounds:
LEGITIMATE BUSINESS INTERESTS
We may use and process Your data for Our legitimate business interests, which include, among other things, communicating with You, improving Our goods or services, improving Our website, and providing You with the information or products that You have requested.
Performance of a Contract: We may use and process Your information to enter into a contract with You and to perform Our contractual obligations to You.
Consent: We may use Your data, or permit selected third parties to use Your data, based on Your consent to Our use and sharing of that data. You may withdraw Your consent at any time, but doing so may affect Your ability to use Our website or other offerings.
As required by law: We may also use or process Your data as required for Us to comply with legal obligations.
WHY WE DISCLOSE YOUR INFORMATION
The following are specific reasons why We may share Your information:
Third Party Processing: We may disclose Your information to third parties who assist Us with various tasks, including payment processing, hosting services, email delivery, communications, and customer service. We may not always disclose these third-party processors if not required by law. We do not authorize them to use or disclose Your personal information except in connection with providing Our company with their services.
By Law: We may share Your data as required by law or to respond to legal process, including a subpoena, or as necessary to protect the rights, property, and safety of others. This includes sharing information with other parties to prevent or address fraud and to avoid credit risks.
To Protect Our Company: We may use Your information to protect Our company, including to investigate and remedy any violations of Our rights or policies. We may also disclose Your information as reasonably necessary to acquire and maintain insurance coverage, manage risks, obtain financial or legal advice, or to exercise or defend against legal claims.
Advertisers: We may use third-party advertising companies to run and manage Our ads on Facebook and Instagram to produce ads that appears when You visit Our website or mobile app. These companies may use information about Your visit to Our website and other websites that are contained in web cookies (as described below) to offer You personalized advertisements about goods and services that might interest You. We cannot control the activities of such other advertisers or web sites. You should consult the respective Privacy Policies of these third-party advertisers for more detailed information on their practices as well as for instructions about how to opt-out of certain practices.
Please note that, at this time, We do not recognize automated browser signals regarding tracking systems, which may include “do not track” instructions.
Other Third Parties: We may share information with advertisers, Our investors, or other third parties for the purpose of conducting general business analysis. If We do so, We will make reasonable efforts to inform You if required by law.
Interaction With Others: If You interact with others on Our website or mobile app, such as participating in a group chat or a group online course, other users may have access to some of Your data, including Your name, profile picture, and Your history of interaction with Our website, such as prior comments or posts.
Online Postings: When You post online, Your posts may be viewed by others, and We may distribute Your comments outside the website.
External Links: Our website may include hyperlinks to other websites not controlled by Us. We suggest You exercise caution when clicking on a hyperlink. Although We use reasonable care in including a hyperlink on Our own web page, We do not regularly monitor the websites of these third parties and are not responsible for any damage or consequences You suffer by using these hyperlinks. We are not bound by the Privacy Policies of any third-party website that You access by a hyperlink, nor are they bound by ours. We encourage You to read the Policies of those third-party websites before interacting with them or making purchases. They may collect different information and by different methods than We do.
Other Purposes: We may disclose Your personal data as necessary to comply with any legal obligation or to protect Your interests, or the vital interests of others or Our company.
HOW INFORMATION IS STORED AND SHARED
You have the right to know what information is stored (and not stored) and how it is processed. Your information is stored through a data management system, and it is important to us to take appropriate measures to ensure your information is kept confidential. You understand that there are limited purposes where we will share your confidential information, including with those who are providing technical support for our website, or those who are members of our team, including legal and accounting. Any parties who will have access to your information will keep such information confidential and will never share with any unrelated parties to the best of our abilities. information provided by you will never be shared, sold, or given to any other company or person without your consent, other than what is required to complete a purchase or request you have made, unless required to do so by law, or any governmental requirements. We require all such third parties to treat your personal information in accordance with the law, and only allow them to process your personal data for specific, necessary purposes.
Please be aware we may disclose information provided if we are required to do so by law, or if there is an honest, good faith belief that such disclosure is necessary to protect the rights of our website or of Ana Sanson that any portion of our policies are being violated, to prevent or mitigate a belief that a crime may being committed, or to protect that safety or rights of our other uses. This information may also be shared as a result of the sale of Ana Sanson, LLC or any branch of the company, as well as with any joint venture partners or affiliate marketers, should we deem it necessary to share such information. We will always take all reasonable measures to protect and safeguard your information.
By collecting and using your personal data, We are acting as a data controller, meaning we determine what information is collected, how long it is stored, and what the Personal Information will be used for. We utilize a third-party company to act as a data processor, which stores information such as names and email addresses that make up our email list. To the best of our ability, we have researched and concluded that all third party data processors we use have advised us they are compliant with the General Data Protection Regulations as well.
Log Files: Like many other websites, We make use of log files. These files merely log visitors to the site – usually a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks. This information is used to analyze trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses and other such information are not linked to any information that is personally identifiable.
We may use any or all of the following types of cookies:
Essential Cookies: These cookies help Us run Our website and improve Your experience with Our website. These cookies may allow content to load more quickly or allow You to access “members only” or repeat-users sections of Our website.
Functionality Cookies: These cookies allow Us to remember Your preferences from earlier visits to Our website, including login information, so that You do not have to input the same information multiple times.
Social Media Cookies: These cookies allow Us to record when You have engaged with a social media tool while visiting Our website. For example, We may record that You have “liked” a certain aspect of Our website. The social media application may also share data with Us that You have allowed it to share. If You wish to change Your social media sharing settings, please visit the privacy settings of the social media network.
Advertising Cookies: We may work with third-party advertising partners who collect information about Your browsing habits on Our website in order to later display a relevant ad about Our services when You are on a third-party site such as a social media platform. These cookies may also allow Us to access Your location.
Pixel Tags: We may use a pixel tag, which is a small graphic file that allows Us to monitor the use of Our website and provide Us with information regarding Your interaction with the website. These tags may collect the IP address from the device You are using, and the browser type.
Pixel tags are also used by Our third-party partners to collect information when You visit Our website, and We may use this information to display targeted advertisements.
Email Confirmations: We may receive email confirmations when You open an email from Us. This allows Us to determine if users are responding favorably to Our email communications and to improve those communications.
Other Technologies: Other data technologies may be used that collect comparable information for security, fraud detection, and similar purposes, to give Us information about Your use of Our website, and to greater improve Our website and service offerings to You.
Facebook: You can opt-out of Facebook’s interest-based ads by visiting: https://www.facebook.com/help/568137493302217.
PROCESSING YOUR INFORMATION
For the most part, We do not process Your information in-house, but give it to third-party processors for processing. For example, when PayPal takes Your payment information, they are a third-party processor. They process Your payment and remit the funds to Us. So in many instances, it will be necessary for Us to transmit Your information to a third-party processor, as We do not have the capability to perform these functions. More detail on third-party processing is detailed below.
However, We may, from time to time, process Your data internally. The legal basis for this processing is both Your consent to the processing, Our need to conduct Our legitimate business interests, and to comply with legal obligations. Our purposes in processing this information, if We do, is to administer, maintain, and improve Our website and offerings, to enter into contracts with You, to fulfill the terms of those contracts, to keep records of Our transactions and interactions, to be able to provide You with goods and services, to comply with Our legal obligations, to obtain professional advice, and to protect the rights and interests of Our company, Our customers (including You), and any third parties. We may process the following data:
- Data associated with Your account, such as Your name, address, email address, and payment information.
- Data about Your usage of Our website, such as Your IP address, geographical information, and how long You accessed Our website and what You viewed.
- Data related to Your personal profile, such as Your name, address, profile picture, interests and hobbies, or employment details.
- Data that You provide Us in the course of using Our services.
- Data that You post on Our website, such as comments or responses to blogs.
- Data that You submit to Us when You make an inquiry regarding Our website or offerings.
- Data related to Your transactions with Us, including Your purchase of Our goods or services. This information may include contact details and payment information.
- Data that You provide to Us when You subscribe to Our emails or newsletters, including Your email address and contact information.
- Data that You submit to Us via correspondence, such as when You email Us with questions.
- Any other data identified in this policy, for the purpose of complying with Our legal obligations, or to protect the vital interests of You or any other natural person.
Our website is hosted by servers located in the United States of America. Therefore, if You reside outside the United States of America, some of Your data will be transferred internationally to and stored on those servers. In addition, We may use third-party processors (including payment processors) and subcontractors located in the United States of America. We use all reasonable methods to protect the safety of Your data during transfer, including hosting Our website on reputable servers and engaging reputable third-party processors. By using this site and providing Us with information, You consent to this transfer, processing, and storage of Your information in the United States of America. Note that the privacy laws in the United States of America may not be as strict as those in other countries. Please be aware that:
- Data that is provided to Us is stored on secure servers. Payment information and other sensitive data will be encrypted to ensure its safety.
- The transmission of data via the internet is never completely secure, and We cannot guarantee the security of data that is sent to Us electronically. Your transmission of data to Us is at Your own risk.
- Where data that You have transmitted to Us is password protected, You are responsible for keeping the password confidential. You are exclusively responsible for any breaches of Your data that results from Your own disclosure of or failure to protect Your password.
Customer data outside the U.S. may be transferred to Our website servers and/or third-party processors or subcontractors that are located in the U.S.
INFORMATION PROTECTION AND SECURITY
We use commercially reasonable methods to safeguard your personal data, including that which you provide to use, and that which we collect automatically, by using reasonable online security measures, and sharing your data with reputable third party vendors that are compliant with generally accepted security and safety measures. We utilize a Secure Sockets Layer (SSL) on our website in order to assist in the secure transfer of information; however, it can never be guaranteed. Should We become aware that a data breach has occurred, We will timely notify the necessary parties with as much information as we have available.
While our team does our best to protect the information we collect, and prevent any misuse, unauthorized access, or disclosure, you understand that we cannot be responsible should an unauthorized third party obtain access to our information, without our consent. Should our website be tampered with, you understand that your personal information may be accessed by these unauthorized parties. You agree that we are not responsible for any such actions, and acknowledge you will hold us harmless should your information become intercepted in this way without our knowledge, permission, or consent, which includes a release of any and all claims related to use of such information by such an unauthorized party.
We have determined it is not required to appoint a Data Protection Officer, as our core activities do not consist of processing operations that require regular and systematic monitoring of data subjects nor do we process sensitive categories of data on a large scale.
We retain personal data as long as it is needed to to conduct Our legitimate business purposes or to comply with Our legal obligations, or until You ask Us to delete Your data. For example, We will retain certain personal information indefinitely for the purposes of maintaining Your account, unless and until You delete Your account. Data that We gather for a specific and particular purpose, such as assisting law enforcement or analyzing trends, will be kept for no longer than is necessary for that particular purpose. Data that is no longer needed by Us for any of the purposes listed above will be permanently deleted.
We will honor Your request to delete Your data, as described more fully below, unless We are required by law to retain access to the data. However, note that We cannot control the retention policies of third parties. If You wish to have any third parties, including those to whom We’ve transmitted Your data, delete that data, You will need to contact those third parties directly. You may request from Us a list of all third parties to whom We have transmitted Your data.
We may retain usage data (that is, data that is gathered by Our company or third-party analytics companies for the purpose of analyzing the use of Our website) as needed for internal analysis purposes. This type of data is usually retained for a shorter period of time than personal data, unless the data is necessary to improve the security or functionality of Our website or offerings, or We are legally obligated to retain the data for a longer period of time.
SECURITY OF YOUR INFORMATION
We take all reasonable steps to protect Your personal data and keep Your information secure. We use recognized online secure payment systems and implement generally accepted standards of security to protect against personal data loss or misuse. However, no security measure is foolproof, and no method of data transmission can be guaranteed against interception or misuse. We cannot guarantee complete security of any information You transmit to Us.
We will notify You promptly of any known breach of Our security systems or Your data which might expose You to serious risk.
CHILDREN AND COPPA COMPLIANCE
If we learn we have collected or received personal information from a minor under 18, we will delete this information, and/or attempt to obtain parental consent. If you have any reason to believe we may have unknowingly collected data from a minor, please let us know by sending us an email at email@example.com
You have certain rights with respect to Your personal data, as outlined below. Note that We may charge You a reasonable fee for actions that You ask Us to take with respect to Your data. In addition, We reserve the right to request that You provide Us with evidence of Your identity before We take any action with respect to the exercise of Your data rights. Further, Your rights may be restricted or nullified to the extent they conflict with Our compelling business interests, the public interest, or the law.
UPDATE ACCOUNT INFORMATION
You have the right to update or change any information You have provided to Us. To update or delete Your information, please contact Us at firstname.lastname@example.org.
CONFIRM PERSONAL DATA AND ITS USE
You have the right to request that We confirm what data We hold about You, and for what purposes. You also have the right to confirmation of whether We process Your data or deliver Your data to third-party processors, and for what purposes. We will supply You with copies of Your personal data unless doing so would affect the rights and freedoms of others.
Change Consent: You have the right to change Your consent to Our use of Your information. In such cases, We may require You to delete Your account with Us, as described above, and You may not have full access to Our website.
Request a Copy of Data: You have the right to request a digital copy of the data that We hold about You. Your first request for a copy of Your personal data will be provided free of charge; subsequent requests will incur a reasonable fee.
Transfer Your Data: You have the right to request that We gather and transfer Your data to another controller, in a commonly used and machine readable format, unless doing so would cause Us an undue burden.
Delete All Data: You have the right to request that We delete all data that We hold about You, and We must delete such data without undue delay. There are exceptions to this right, such as when keeping Your data is required by law, is necessary to exercise the right of freedom of expression and information, is required for compliance with a legal obligation, or is necessary for the exercise or defense of legal claims. Such a request may result in a termination of Your account with Us and You may have limited or no use of Our website.
Emails and Communications: You may opt out of receiving future email correspondence from Us by checking the appropriate box when You register for the account or make a purchase. You may change Your communication settings by contacting Us at email@example.com.
Marketing Communications: You may opt out of receiving any third-party marketing communications or having Your personal information used for marketing purposes. You may do this by contacting Us at firstname.lastname@example.org.
Processing: You may, in some circumstances, restrict the processing of Your data, such as when You contest the accuracy of Your data or when You have objected to processing, pending the verification of that objection. When processing has been restricted, We will continue to store Your data but will not pass it on to third-party processors without Your consent, or as necessary to comply with legal obligations or protect Your rights or those of others or Our company. In addition, You may opt out of any processing of Your data altogether. Note, however that doing so may result in the termination of Your account and loss of access to Our website.
We offer the opportunity for You to volunteer certain information to Us that is used for email and marketing purposes. This information includes, but is not limited to, Your name and email. You will have an opportunity to unsubscribe from any future communications via email, but We reserve the right to maintain a database of past email subscribers. We reserve the right to use this information as reasonably necessary in Our business and as provided by law. Your information will be shared with reasonably necessary parties for the ordinary course of conducting Our business, such as through Facebook ads or Google Pay Per Click marketing campaigns.
Should you have any questions with respect to any of the foregoing, please contact us at email@example.com.