Privacy Policy

EFFECTIVE DATE: April 8, 2024

The website www.ConsciousStrategies.com (“Site”) and all the information and materials you encounter on it (collectively referred to as “Content”), are owned, operated, and controlled by Lynnette Brown of Conscious Strategies (“Company,” “we,” “our,” or “us”).  This Content includes text, pictures, videos, audio files, emails we send you, forms, documents, templates, and similar items.  We are committed to respecting the privacy rights of our customers, clients, visitors, and other users of the Site.  This Privacy Policy (“Policy”) constitutes an agreement between the Company and you, as the user of the Site (“you” or “your”).  The terms “you” or “your” encompass anyone using, visiting, or viewing our Site.

PURPOSE OF PRIVACY POLICY

This Policy outlines its effective date, the information we may collect from you and how, how we might use and disclose that information, your rights concerning that data, procedures for reviewing or changing your provided personal information, how we may change this Policy, and our measures to secure your information — while complying with applicable data protection laws, including the European Union General Data Protection Regulation (“GDPR”), California Consumer Privacy Act (“CCPA”), California Privacy Rights Act (“CPRA”), CAN-Spam Act, and Children’s Online Privacy Protection Act (“COPPA”).  Furthermore, we adhere to the principle of data minimization.  Accordingly, we only collect, use, and disclose your information as necessary to fulfill the purposes outlined in this Policy, and we will not collect or retain your information for any longer than is required for these purposes.

This Policy only applies to our Site, email communications, and any offline location where we display it.  Furthermore, our Site may contain links to third-party websites and include embedded content (e.g., videos, images, text, etc.) that behaves similarly to how it would be if you visited the third-party website.  This Policy does not apply to third-party websites.  Links to third-party websites and embedded content are not part of our service and are beyond our control.  This includes links from our partners that may use Company’s logos as part of a co-branding agreement.  If you choose to visit third-party websites or use embedded content, we are neither responsible nor liable for their privacy practices, activities, or content, and it is your responsibility to review their privacy policies to confirm you understand and agree with it.  Your visits and access to third-party websites is at your own risk.  Please note that third-party websites may send their own cookies to users, collect data, or solicit personal information.  Additionally, this Policy doesn’t address aspects inherent to the Internet that are beyond our control, nor does it override applicable laws or governmental regulations.

By continuing to access or use our Site, you indicate your acceptance of this Policy.  If you disagree with any part of this Policy, please refrain from using our Site and exit immediately.

INFORMATION COLLECTION PRACTICES

WHAT INFORMATION DO WE COLLECT?

We collect information from you in primarily one of two ways: information you voluntarily share with us (“personal information”), and information automatically gathered through technology (“general information”) (collectively “information”).

1. Personal Information You Voluntarily Provide: We may ask you for certain information referred to on this Site as “personal information.” This information pertains to your identity and may include, but is not limited to, your name, address, email address, phone number, date of birth, age, gender, billing and financial information, and other details that can be linked to you.  All activities in which you may engage on this Site are voluntary, except those that are automatically collected through technology, as provided below.  You are not required to provide any personal information to us unless you choose to access features on the Site that require such information.  If you choose to provide your personal information, we promise to use it only for the purposes for which it was provided, and we won’t use it for any other unrelated purposes without your consent. Examples of how you might provide us with your personal information include, but is not limited to:
   • Opting In to Receive Resources, Information, or Downloads: You may provide your contact information to receive such materials as whitepapers, eBooks, or other downloadable content.
   • Subscribing to our Services or Newsletter/Email List: When you sign up to receive updates, resources, or information from us, you may provide your name and email address.
   • Registering for an Account: If you create an account on our Site, you may be asked for information such as your name, email address, username, and password.
   • Making a Purchase: When you purchase a product or service through our Site, you may provide your name, billing address, shipping address, email address, phone number, payment card details, and other information necessary to complete your transaction. Your payment card details are securely processed by our third-party payment processors and are not stored or retained by us.
   • Sharing Content: You may choose to share content or leave comments on our Site. This may include uploading media or providing your name, email address, and any other information you include in your message.  Please note, our Site may feature interactive forums such as commenting on a blog or social media platforms. Please be aware that any information or comments disclosed in these areas become public information, and you should exercise caution when deciding to disclose your personal information.  We are not liable for any third-party misuse of the information you make public.
   • Contacting Us: When you contact us, whether by email, phone, mail, chat, social media, our website’s contact form, or any other means, we may collect the personal information you provide to assist you with your inquiry.
   • Filling Out a Form: Our Site may offer various forms for you to request information, download resources, or provide feedback. These forms may collect information such as your name, email address, and any other details relevant to the form’s purpose.
   • Participating in Promotions or Events: If you enter a contest, sweepstake, or other promotion, or register for a webinar, course, or event, you may provide your name, email address, phone number, and other relevant details.

1. General Information Automatically Gathered Through Technology: There may be instances in which we automatically collect information from you that is more general and technical in nature (“general information”).  When you visit our Site, we may automatically gather information about your device and browsing activities.  This information, which is not personally identifiable, may include, but is not limited to:

• Device Information
  1. IP Address: An Internet Protocol (IP) address is a unique number assigned to each device connected to the Internet. It acts like a mailing address for your device on the Internet, allowing information to be sent and received. We use your IP address to understand your location data, such as what region you are generally connecting from (e.g., city, state, country), but we do not use it to identify you personally.
  2. Browser Type: This refers to the software you use to access the Internet, such as Chrome, Firefox, Safari, etc. Knowing your browser type helps us ensure the website functions properly for you.

• Operating System: This is the software that runs your device, such as Windows, Mac OS, Android, iOS, etc. Understanding your operating system helps us optimize our Site’s performance for your device.

1. Mobile Device Information (if applicable): If you visit our Site on a smartphone or tablet (on some devices, Site functionality may be limited) we may collect information about your mobile device, such as its IP address, browser type, operating system, and other similar data.
2. Other similar device data.

• Browsing Activity:
  1. The pages you visit: This helps us understand which content on our Site is most popular and interesting to users.
  2. Time spent on pages: Knowing how long you stay on a page helps us gauge how engaging our content is.

• Clickstream data (server address and domain name): This is a record of the path you take as you navigate through our Site. It helps us understand how users interact with the Site and identify areas for improvement.

1. Referring URLs: The web page address that linked you to our Site. This helps us understand how users are finding our Site.
2. Other similar browsing data.

HOW DO WE COLLECT YOUR INFORMATION?

1. Personal Information You Voluntarily Provide: We collect your personal information when you choose to provide it to us. This includes when you interact with our Site (downloading resources, leaving comments), communicate with us directly (email, phone calls), register for an account, make purchases, subscribe to our services, participate in promotions or surveys, or provide feedback.  Please note, browsing our Site does not require you to provide any personal information.  By voluntarily sharing your personal information, however, you consent to its collection and use as described in this Policy.
2. General Information Automatically Gathered Through Technology: We may collect information indirectly through your browser or device when you engage with our services, using cookies and other similar tracking technologies — like web beacons and pixels.
   • Cookies: We collect this information using cookies, tiny data files stored on your device by websites you visit, primarily to enhance your browsing experience and provide you personalized content. You can control or disable cookies through your browser settings, but some features of the Site may not work as intended if you do. Two types of cookies include:
     1. Standard Cookies (HTTP or Browser Cookies): These are the most common type of cookie. They are stored within your web browser and typically store text-based data such as user preferences or session IDs. You can easily manage them through your browser settings, and they can be either session-based (temporary cookies that are erased from your device when you close your web browser) or persistent (cookies that remain on your device for a predetermined period set by the website, even after you close your browser).
     2. Flash Cookies (Local Shared Objects or LSOs): Although less popular, Flash cookies are stored within Adobe Flash Player on your device, not your browser. They offer more capabilities and are often used for tracking user behavior across websites and storing multimedia data.  Although standard browser cookies are managed through the browser’s settings, Flash cookies are managed separately through Adobe Flash settings and can store more information than standard cookies.
   • Web Beacons: Web beacons (also known as tracking pixels or web bugs) are tiny graphic elements embedded within web pages or emails. These invisible elements work with cookies to monitor user activity, such as page views or clicks. When a user interacts with a web beacon, it transmits data back to a server for analysis.  This helps us understand how users engage with our Site and emails.
   • Social Media Pixels: Unlike web beacons, social media pixels are specific tracking elements used by social media platforms like Facebook, Twitter, or LinkedIn. Embedded within web pages or emails, they track user interactions with content related to those platforms, such as likes, shares, or comments. This data helps social media advertisers or content creators measure the effectiveness of their campaigns and target their audience more precisely.
   • Please note, we may use cookies and other tracking technologies, including web beacons and social media pixels, to understand your preferences, improve your experience on our Site, and remember your login credentials (if applicable). Disabling cookies or tracking technologies might limit your Site experience and prevent certain features from functioning as intended.
   • Do Not Track Signals: Do Not Track (“DNT”) signals are requests from users to websites, asking them not to track their online activities, such as browsing behavior and interactions with websites. Please note that our Site does not currently respond to DNT signals or similar mechanisms from web browsers. Although we do not directly honor DNT signals, we provide alternative options for managing your online privacy preferences, such as adjusting your browser settings to control tracking, opting out of certain tracking technologies, utilizing privacy-focused browser extensions or tools, or otherwise detailed in our Policy.

• Information From Other Sources: We may collect information from third-party sources, in accordance with this Policy and applicable laws and regulations. These sources may include, but are not limited to:
  • Advertising networks, service providers, affiliates, business partners, data analytic providers, operating systems and platforms, social networks, public forums (particularly when you mention or reference us), and other third-party sources.
  • Use of Google Analytics and Google Ads: We utilize Google Analytics and on occasion Google Ads to gather information on how users interact with our Site. This information may include your location, browsing history, traffic pattern, pages you visit, how long you spend on each page, the links you click, the information you search for on our Site, the equipment used to access the Site, along with other general information. This data is used to improve our Site and deliver targeted advertising.  It’s important to note that the information collected by Google Analytics and Google Ads is anonymized and cannot be used to directly identify you.  By continuing to use our Site, you consent to the collection and use of information by Google Analytics and Google Ads as described in this Policy.  However, if you’d like to opt out of cookies, you can visit the Google Analytics Opt-out Browser Add-on page here: https://tools.google.com/dlpage/gaoptout. For more details about Google Analytics and Google Ads, please visit these links:
    1. Google Analytics: https://marketingplatform.google.com/about/analytics/
    2. Google Ads: https://ads.google.com/home/

HOW DO WE USE YOUR COLLECTED INFORMATION?

We may use your collected information for various purposes, including but not limited to:

1. Improving Our Site and Products/Services: We may use your information to improve and optimize our Site, products, and services. This may include:
   • Analyzing user interactions, trends, and preferences to better understand your needs.
   • Conducting research or surveys to gather user feedback.
   • Better presenting relevant Site content.
   • Improving Site features and functionalities.
   • Analyzing Site traffic and user behavior (in aggregate and anonymously) to improve our offerings and personalize your experience.
   • Developing new products and services.

1. Delivering Personalized Service: We may use your information to provide and personalize the services you request, including:

• Fulfilling orders, processing transactions, providing download/information requests, and delivering products or services requested by users.
• Sending you relevant information and updates (with your opt-in consent, which you can unsubscribe to).

1. Personalizing Your Experience: We may use your information to personalize your experience on our Site, including:

• Tailoring and recommending content and offerings to your interests.
• Remembering your preferences (language settings, etc.) and keeping you logged in (if applicable).

1. Marketing and Communication: We may use your information to communicate with you and personalize your experience, but only with your consent.  This includes:

• Responding to your inquiries and providing customer support.
• Sending you administrative information and promotional materials (e.g., email newsletters) that align with your interests.
• Providing benefits to email subscribers, such as free resources, expert advice, updates, news about promotions, and opportunities for community engagement.
• Tailoring advertisements or content based on your preferences (where permitted).

1. Security, Legal Compliance, and Administrative Purposes: We may also use information for essential security, legal, and administrative purposes, including:

• Complying with legal obligations and enforcing our Terms of Use, Terms and Condition, and other agreements.
• Fulfilling contractual obligations.
• Protecting the security of our Site, users, and their personal information.
• Detecting and preventing illegal activities (e.g., fraud) or misuse of our Site.
• Verifying user identity and qualifications when necessary.

1. Other Purposes with Consent: We may also use your information for other purposes disclosed at the time of collection or with your specific consent.

HOW DO WE DISCLOSE YOUR INFORMATION?

We are strongly committed to not sharing personal or general information with third parties and generally do not disclose such information, unless one of the following circumstances applies:

1. Service Partners: We may disclose your information to third parties with whom we have contractual arrangements, including subsidiaries, affiliates, service providers, marketing partners, contractors, vendors, and other entities (collectively referred to as “Service Partners”). Our Service Partners may utilize your personal information to operate our Site and deliver their services.  For example, your data may be transmitted to our website hosting partners, cloud storage providers, payment processors, email service providers, website analytics providers, automated spam detectors, and other entities assisting us in designing and operating our Site, executing our products/services, or analyzing collected data.  These entities will solely utilize your data for the agreed-upon work and are obligated to maintain confidentiality.  While we encourage our Service Partners to adopt and disclose privacy policies, the utilization of your personal information by them is governed by their respective privacy policies and is beyond our control.
2. Legal Compliance: We may disclose your information when required by law, such as to comply with a court order, subpoena, or other legal process. This may also include sharing information to enforce intellectual property rights (e.g., copyright or trademark).

• Protection: We may also disclose your information to protect the rights, property, or safety of our business, our clients, customers, employees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, information security, preventing imminent harm to any person or entity, and other related matters.

1. Enforce Agreements: We may disclose your information to enforce or apply our terms of use, terms and condition, and other agreement.
2. Sale of Our Assets: We may disclose your information in the event of a merger, acquisition, or any form of sale of some or all our assets, in which case the personal or general information we collected via the Site will be among the assets transferred to the buyer.
3. Consent: We may disclose your information with your consent.

HOW DO YOU ACCESS AND CONTROL YOUR INFORMATION?

1. Review and Update Your Information: To confirm that your Personal Information remains correct and updated, you may email us at LBrown@ConsciousStrategies.com and request to review and update your Personal Information on file; manage your communication preferences, including opting out of Company updates or promotional materials from our partners; and request deletion of your personal information, though some limitations may apply.
2. Unsubscribe from Emails: At any time, you may unsubscribe from receiving further communications from us by clicking “unsubscribe” at the bottom of our emails, replying with “UNSUBSCRIBE” in the subject line, or contacting us directly at LBrown@ConsciousStrategies.com.  Please note, you may need to unsubscribe from each list you’ve subscribed to individually.
3. Account Security: If you create an account on our Site with a username and/or password, to protect your account and information, do not share your login credentials. You are solely responsible for all activity that occurs under your account.  Accordingly, we recommend logging out after each session to minimize the risk of unauthorized access.  Additionally, if you believe your credit card information, username, or password has been lost, stolen, or used without your permission, contact us immediately to ensure your account security.

HOW DO WE STORE YOUR INFORMATION?

We take the security of your information very seriously.

1. Storage: We employ secure storage practices to safeguard your information. This includes using industry-standard safeguards to protect your data while it’s stored on our systems.
2. Data Retention: We retain your information for as long as necessary to fulfill the purposes for which it was collected, as outline in this Policy, unless a longer retention period is required or permitted to comply with legal, accounting, reporting, dispute resolution, or enforcement of our agreement requirements. The specific retention period for different types of information may vary based on the nature of the information and the purposes for which it is processed.  Once the retention period expires, we will securely delete or anonymize your personal information in a manner that prevents its reconstruction or restoration. For example:
   • Transaction and account data: Retained for as long as your account is active or to provide services. We may also retain this data for legal or compliance reasons.
   • Usage data: Retained for a reasonable period to analyze trends, improve our services, and personalize your experience. However, we take steps to anonymize this data.
   • Customer support data: Retained for a reasonable period to address any issues and improve support services.
   • Inactive account data: Held for a limited time to allow reactivation or comply with legal requirements.

• Security: We take reasonable precautions to protect your information from loss, misuse, and unauthorized access, alteration, or disclosure. However, we cannot guarantee the absolute security of any information transmitted through this Site.  By using this Site, you acknowledge that you understand and assume these risks.  We are not liable, and you agree to hold us harmless, from any security breaches, unauthorized use of your information by third parties, or disclosure of your information that arises beyond our reasonable control.

WHAT ARE YOUR EMAIL MARKETING RIGHTS?

We may use email marketing to keep our subscribers informed and engaged.  You can choose to subscribe to receive emails with exclusive content to updates, promotions, special offers, tips, and free resources tailored to your interests.  We prioritize your privacy and will never share, sell, or trade your information with third parties unless explicitly stated in this Policy.

We comply with both GDPR (General Data Protection Regulation) and CAN-SPAM Act (Controlling the Assault of Non-Solicited Pornography and Marketing Act) of 2003 for email marketing practices.

1. GDPR: Under GDPR, we require affirmative consent from individuals before sending marketing emails, emphasizing transparency, individual rights, and data protection principles. This means that individuals must actively opt-in to receive marketing communications from us.  Additionally, GDPR grants individuals enhanced rights over their personal data, including the right to access, correct, and delete their data. (More on GDPR forthwith.)
2. CAN-SPAM: In contrast, although CAN-SPAM allows sending commercial emails without prior consent, it focuses on regulating the behavior of commercial email messages, such as prohibiting deceptive subject lines or headers, and requiring clear sender identification with a valid address, as well as clear opt-out mechanisms.

• We respect your privacy and control over your inbox: To comply with both regulations and ensure transparency, we:
  • Require your consent:We only send marketing emails to users who actively opt-in to receive them.
  • Make unsubscribing easy:Every marketing email we send includes a clear and functional unsubscribe mechanism as indicated in this Policy, which we promptly honor all unsubscribe requests.
  • Provide clear sender information:Our emails will identify us as the sender and include our contact information and a relevant subject line.

GENERAL DATA PROTECTION REGULATION (GDPR)

If you are located in the European Union (“EU”) or the European Economic Area (“EEA”), the GDPR may grant you certain additional rights regarding your personal data, including:

1. Right to Access: You have the right to request a copy of the personal data we hold about you.
2. Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.

• Right to Erasure (Right to be Forgotten): Under certain circumstances, you have the right to request that we erase your personal data.

1. Right to Restrict Processing: You have the right to request that we restrict the way we process your personal data.
2. Right to Data Portability: You have the right to request that we transfer your personal data to another organization.
3. Right to Object: You have the right to object to how we use your personal data, including for marketing purposes.

We are committed to protecting your privacy and complying with the GDPR.  When you provide us with personal information, we ensure it is used lawfully, fairly, and transparently.  We collect and process your data only for specified, explicit, and legitimate purposes, and we do not process it further in a manner incompatible with those purposes.  Your personal data is kept accurate and up-to-date, and we take appropriate measures to ensure its security.  We will not transfer your personal data outside the EEA without adequate safeguards in place.  Additionally, you have the right to access, rectify, or erase your personal data, as well as the right to restrict or object to its processing, and data portability.  If you have any questions or concerns about our data processing practices or wish to exercise your rights under GDPR, please send an e-mail message to LBrown@ConsciousStrategies.com.

FOR RESIDENTS OF CALIFORNIA

SHINE THE LIGHT

Under California’s “Shine the Light” law, California residents who provide personal information to acquire products or services for personal, family, or household use are entitled to request and obtain from us, once each calendar year, information about what customer information we shared, if any, with other businesses for their own direct marketing uses.  If applicable, this information would include categories of customer information and the names and addresses of those businesses with which we shared customer information during the immediately preceding calendar year.

To request this information, please email LBrown@ConsciousStrategies.com with “Request for California Privacy Information” in the subject line and in the body of your message.  We will provide in response the requested information to you at your email address.

Please note, not all information sharing is covered under the “Shine the Light” requirements, and only required information will be included in our response.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND CALIFORNIA PRIVACY RIGHTS ACT (CPRA)

The California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (CPRA) provide additional rights to residents of California regarding our information collection and use practices.

1. CCPA: The CCPA (2020) stands as the foundation for consumer privacy rights in California, granting residents the right to know, access, and delete their personal information collected by businesses, along with the right to opt-out of the sale of such information.
2. CPRA: The CPRA (2023) builds upon the CCPA, strengthening existing rights and adding new ones. It includes:
   • Right to Correct: Allows requesting to correct inaccurate data.
   • Right to Limit Use and Sharing: Grants more control over how your data is used and shared with third parties, including the right to limit the use of personal information.
   • Right to Data Portability: Increased ease for requesting your data to be transferred to another business.
   • Broader Definition of “Sale”: Clarifies the selling of personal information, including sharing for valuable considerations.
   • Establishment of CPPA Agency: Creates the California Privacy Protection Agency (CPPA) to oversee enforcement.

• Our Commitment: We are committed to complying with both the CCPA and CPRA and respecting the privacy of our California users. Here’s how our Policy reflects these rights:
  • Transparency: We disclose the categories of personal information we collect and how we use it in our Policy. Below, we identify the categories of personal information we may have collected about our users in the last 12 months (using the categories provided in the CCPA):
    1. Identifiers: This category includes information that can directly or indirectly identify you, such as your name, address, email address, phone number, IP address, or other unique online identifiers. Identifiers may also include sensitive personal information, such as your social security number or driver’s license number, but we do not collect sensitive personal information.
    2. Customer Records Information: This category includes information about your purchases, services obtained, or considered, such as billing and payment history, product or service purchase history, or warranty information.

• Characteristics of protected classifications under California or federal law: This category includes information about protected characteristics like race, ethnicity, religion, gender, sexual orientation, age, disability status, or other similar characteristics that are protected from discrimination under California or federal law. We, however, do not collect this information.

1. Commercial Information: This category includes information about your product/service usage, purchasing habits, or tendencies, such as records of products or services purchased, browsing history (related to our Site or service), or search history (related to our Site or service). We collect this information when applicable.
2. Biometric Information: This category includes data about your biological, physiological, or behavioral characteristics used for identification, such as fingerprints, facial recognition data, or voiceprints. We do not collect this information.
3. Internet or Other Electronic Network Activity Information: This category includes information about your interactions with our Site or service, such as your IP address, browsing history, search history, information collected through cookies and similar tracking technologies, or app usage data (if applicable).

• Geological Data: This category includes information about your physical location, such as GPS coordinates or IP address (may provide general location information).
• Audio, Visual, Electronic, Thermal, Olfactory, or Similar Information: Although unlikely to collect, this category includes recordings of audio or visual information, electronic communications, thermal images, scent information, or other similar data.

1. Professional or Employment-related Information: This category includes information about your professional background, such as employment history, qualifications, professional licenses or certifications, performance evaluations, or other similar professional or employment-related information (if applicable).
2. Educational Information: This category includes information about your educational background, such as school name, grades, or degrees obtained. We do not collect this information.
3. Inferences: This category includes information derived from other collected information to create a profile about you, such as preferences, characteristics, abilities, attitudes, or behavioral tendencies.

• Please note, we may not collect all the categories of information listed. The specific information collected depends on how you interact with our Site or products/services. For more detail about the information we collect and its sources, please refer to our Information Collection Practices section within this Policy.  We use this information only for the purposes outlined in that section.

• Rights to Know, Access, Correct, and Restrict:As stated in this Policy, you have the right to know and can request access to, correct, or restrict the use and sharing of your data with third parties, as well as data portability of your personal information by contacting us via email at LBrown@ConsciousStrategies.com. We may require specific information from you to help us verify your identity and process your request.  If we are unable to verify your identity, we may deny your request.  Regarding the right to know, you have the right to know certain details about our data practices in the past 12 months.  You may request details on:
  1. The categories and specific pieces of personal information we hold about you.
  2. The sources we collect this information from.

• The categories of information we disclosed or sold for business purposes, and the recipients.

1. The business or commercial purpose for collecting or selling your information.

• Right to Delete: Subject to statutory exemptions and exceptions, you have the right to request that we delete the personal information we have collected from you in the last 12 months. To exercise your Right to Delete, please email LBrown@ConsciousStrategies.com. We may require specific information from you to help us verify your identity and process your request.  If we are unable to verify your identity, we may deny your request.  If we deny your request, we will explain the reason why in our response.  Additionally, we may not be able to delete all information if required for legal obligations, dispute resolution, or enforcing our agreements.
• Right to Opt-Out:The CCPA and CPRA grant you the right to opt-out of the sale or sharing of your personal information. We do not currently sell your personal information as defined by CCPA and CPRA.  If this changes, we will provide clear opt-out mechanisms on our Site and in which case, you may submit a request to opt-out by clicking Do Not Sell My Personal Information or by sending an e-mail message to LBrown@ConsciousStrategies.com.  We will verify your request and respond reasonably.  Opting-out won’t affect your use of our Site or service unless it relies on the information you previously opted out of sharing.  Additionally, if you are a California resident and we know you are under 18 years of age, we will not sell your personal information unless (i) you are 13 years of age or older and have provided opt-in consent and confirmed that choice, or (ii) you are under 13 years of age and your parent or guardian has provided affirmative authorization of that sale.  If you or your parent or guardian has provided opt-in consent (dependent on age), you can change your mind at any time by sending an e-mail message to LBrown@ConsciousStrategies.com.
• Right to Non-Discrimination:You will not be discriminated against for exercising your rights.
• Authorized Agent: You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
• Notice Of Financial Incentives: Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them. We currently are not offering financial incentives.

HOW DO WE PROTECT CHILDREN’S PRIVACY?

We understand the sensitive nature of children’s privacy online and are firmly committed to its protection.  Our Site is intended for a general audience of individuals aged 18 and over.  We do not direct any of our content at children under 18 years of age.

We do not knowingly collect personal information from individuals under the age of 18.  If you are under the age of 18 and your parent or guardian has not provided verifiable parental consent, do not provide any personal information.  Personal information submitted by one under the age of 18 without prior verifiable parental or guardian consent will not be accepted.  If we learn or have reason to suspect that a Site user is under age 18 without prior verifiable parental or guardian consent, we will promptly delete any personal information in that user’s account.  If you are a parent or guardian and become aware that your child has provided us with personal information, please send an e-mail message to LBrown@ConsciousStrategies.com so we can take appropriate action to remove such information from our records.  Please include your child’s name and any relevant details in your request.  We will take steps to verify your identity and process your request promptly, in accordance with applicable laws and regulations.

We may collect certain non-personally identifiable information (e.g., browsing data collected through cookies) during a user’s visit, regardless of age.  This information is used for general Site analytics purposes, such as understanding traffic patterns and improving user experience, therefore it may be used as indicated in this Policy.  We do not use this information to identify individual users or create user profiles.

Our Policy complies with the following:

1. Children’s Online Privacy Protection Act (COPPA):
   • The United States’ Federal Trade Commission, which strives to protect consumers and promote competition in the marketplace, enforces COPPA. Under COPPA, websites or online services directed at children under 13 years of age, and either collecting personal information from them OR allowing others to do so, must comply with COPPA’s requirements. Furthermore, COPPA requirements apply to websites or online services directed to a general audience, but have actual knowledge that they collect personal information from children under 13.  Similarly, COPPA also applies to companies running an ad network or plug-in having actual knowledge of collecting personal information from website or service users directed to children under 13.  To help give parents and guardians control over what personal information is collected from their children under age 13, as well as to protect the children’s privacy and safety while using the Internet, such websites and online services must provide privacy policies outlining what and how the personal information of children under 13 years of age is collected, used, and disclosed.  Moreover, the privacy policy must include a description of parental/guardian rights, including the steps for exercising these rights, informing parents/ guardians that only necessary information for their child’s participation is requested, and parents/guardians can review, delete, and restrict further collection or use of such information.  It also permits them to consent to data collection and withhold disclosing such information to third parties unless it’s part of the service. Furthermore, they are required to obtain verifiable parental/guardian consent before collecting, using, or disclosing the personal information of children under 13.  In addition, they must take reasonable steps to ensure the security of the personal information they collect from children.
   • Our Policy complies with COPPA, as we do not knowingly collect, use, or disclose personal information from children under the age of 13 without prior verifiable parental or guardian consent, as we require verifiable parent/guardian consent for anyone under the age of 18. If you believe that the personal information of a child was collected, used, or disclosed, without parental or guardian consent, please send an e-mail message to LBrown@ConsciousStrategies.com so we can have the information deleted. Please include your child’s name and any relevant details in your request.  We will take steps to verify your identity and process your request promptly, in accordance with applicable laws and regulations.
2. California Consumer Privacy Act (CCPA):
   • Our Policy also complies with the California Consumer Privacy Act (CCPA), which is expanded upon forthwith and may provide California residents under 16 years of age with additional rights regarding the collection and sale of their personal information.
   • Under the CCPA, businesses are prohibited from selling or sharing the personal information of California consumers whom they have actual knowledge of being under 16 years of age, unless the child has provided their affirmative authorization (or opt-in consent) to the sale or sharing of their personal information. If the child, however, is under 13, the authorization must come from the child’s parent or guardian.  A business has “actual knowledge” of a consumer’s age if it willfully disregards it.  The renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to another business or third-party for monetary or other valuable consideration is considered selling, whereas if it’s done for generally another purpose is considered sharing.

• Our Commitment: We adhere to these provisions by not only ensuring that we obtain opt-in consent from a parent or guardian if the user is under 13 years of age, before engaging in any selling or sharing of their personal information, but we also require opt-in consent from the parent or guardian of those under 18 years of age.

1. California’s “Eraser Button” Law: Under California’s “Eraser Button” law, California residents under age 18 who have registered to use the Site may request removal of content they have posted. To make a request, please send an email message to LBrown@ConsciousStrategies.com with “Eraser Button” in the subject line and in the body of your message, as well as specifying what content you have posted that you are requesting to remove.

POLICY UPDATES

We reserve the right, at any time, to add to, delete, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any notice to you.  Any such change, update, or modification will be effective immediately upon posting on the Site.  It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all its terms.  Your continued use of the Site after we post any such modification will constitute your acknowledgment of the modified Policy and your agreement to abide and be bound by the modified Policy.  We will also revise the “EFFECTIVE DATE” found at the beginning of the Policy when we post changes to it.

CONTACTING US

If you have any questions or comments about this Policy, our practices related to this Site, or if you would like to have us remove your information from our database, please feel free to contact us at the following e-mail address: LBrown@ConsciousStrategies.com.