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EFT Universe Privacy Policy

GENERAL

Energy Psychology Group, Inc. (“Company” or “we” or “us” or “our”) is publishing this Privacy Policy for its users (“user” or “you”) that use our websites, including other media forms, media channels, platforms, mobile website, or mobile applications related or connected thereto. The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website, you should review any changes since the last time you used the Website.

Notice to Users Outside the United States: The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you may be viewed as transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet (including personal data collection, use and disclosure), different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website. Further, note that your jurisdiction may offer a more limited or different level of protection with respect to the privacy of your data.

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

GATHERING, USE, AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Website Generally

“Non-Personally Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally Identifying Information,” by contrast, is information such as a name or email address that, without more information, can be directly associated with a specific person.

Like most website operators, Company gathers from users of the Website Non-Personally Identifying Information of the sort that web browsers, depending on their settings, may make available. We do this for marketing and security reasons. The information gathered includes the user’s Internet Protocol (IP) address, operating system, browser type, and the locations of the websites the user views right before arriving at, while navigating, and immediately after leaving the Website. Although such information is not Personally Identifying Information, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. We collect and use this information to, for example, calculate how many people visit the Website from certain geographic regions. We do not track or store the full IP address, only the first six digits to track originating country/region, nor do we correlate or store specific IP addresses to a user account or with any unique identifier that will be correlate with a specific user in our system unless you have purchased one of our products or services. Company analyzes Non-Personally Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use.

From time to time, Company may also release the Non-Personally Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

Web Cookies

A “Web Cookie” is a string of information that assigns you a unique identification that a website stores on a user’s computer and that the user’s browser provides to the website each time the user submits a query to the website. We use Cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website, and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners, and others better understand how the Website is being used.

COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES MAY LOSE FUNCTIONALITY OR USE OF CERTAIN FEATURES OF THE WEBSITE.

“Device fingerprinting” can track devices over time, based on your browser’s configurations and settings. Because each browser is unique, device fingerprinting can identify your device, without using cookies. Since device fingerprinting uses the characteristics of your browser configuration to track you, deleting cookies won’t help. Device fingerprinting technologies are evolving and can be used to track you on all kinds of internet-connected devices that have browsers, such as smartphones, tablets, and laptop and desktop computers. For more information please see: https://www.consumer.ftc.gov/articles/0042-online-tracking

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on these Sites, and you waive the right to receive specific notice of each such change or modification.

Web Beacons

A “Web Beacon” or “Pixel Tag” is a small block of code embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages or viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally Identifying Information. They are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web 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 Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Website. These companies may use information about your visits to the Website and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third-party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the instructions and links here: http://www.networkadvertising.org/choices/ and http://preferences-mgr.truste.com, or http://www.aboutads.info/choices. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.

We may allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the Non-Personally Identifying Information we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.

Analytics

We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads help (https://support.google.com/ad/answer/262922?hl=en).

Aggregated and Non-Personally Identifying Information

We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

In addition, Company may make use of de-identified information in accordance with applicable privacy law.

Mobile Device Additional Terms

  • Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and IP address.
  • Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for Company to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
  • Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
  • Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally Identifying Information you submit within the mobile application.

SOCIAL MEDIA 

We may provide you the option to connect your account on the Website to your account on some social networking sites for the purpose of logging in, uploading information, or enabling certain features on the Website. When logging in using your social network credentials, we may collect the Personally Identifying Information you have made publicly available on the social networking site, such as your name, profile picture, cover photo, username, gender, friends network, age range, locale, friend list, and any other information you have made public. Once connected, other users may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By connecting your account on the Website to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the connected social networking site without first disclosing that to you. Each social network may further allow you to set privacy controls around your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore the available features and shared information are subject to change without notice to you.

We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “Tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.

COLLECTION, USE, AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

Website Registration

As defined above, Personally Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally Identifying Information from and about Website users. Much of the Personally Identifying Information collected by Company about users is information provided by users themselves when: (1) registering for our service; (2) logging in with social network credentials; (3) participating in polls, contests, surveys, or other features of our service, or responding to offers or advertisements; (4) communicating with us; (5) creating a public profile; or (6) signing up to receive newsletters. That information may include each user’s name, 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 and activities, your gender, age, date of birth, username, hometown, and other demographic or relevant information as determined by Company from time to time. Users of the Website are under no obligation to provide Company with Personally Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.

BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE, AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Other Kinds of Information: Company collects certain information in various ways from the website and from communications you may have with Company and uses that information in various ways. If you subscribe to our newsletter or if you participate in our Get Started Package or if you participate in our discussion groups, blogs, or other forms of interactivity, among the information that Company may collect are: real names; real addresses including the city, state, and zip code in which you reside; email addresses; telephone numbers; information about your Internet connection; or other information including but not limited to any metadata including personally identifiable and other information. Whether or not you subscribe to our newsletter or participate in our Get Started Package or participate in discussion groups, blogs, or other forms of interactivity, Company may also collect statistics about members, traffic patterns, and related information as well as information gathered from the use of Web Cookies or other technologies, whether from advertisements on the Website or otherwise, and all other such information. All of the foregoing shall be referred to herein as “The Information.” Company shall be entitled to use all the Information for purposes of operating the Website, but Company shall not intentionally sell, lease, or otherwise provide to others the Information except that any credit card information shall be provided to credit card processors for the limited purposes of collecting payments or communicating with credit card companies, PayPal, or similar services, but Company will not be liable for any inadvertent use or disclosure by Company or use by any other parties of the Information. You agree that Company may use and provide to other parties the Information as indicated herein. If you do not agree with the provisions of this paragraph, you should not provide any information to Company.

Usage Information
We collect information about your usage of our services. For example, we collect information about the actions that users perform on the Website, who did what, when, and to what thing on a site (e.g., user logged in [time/date]). As another example, the Website tracks information like the last time you entered a course, where you are at in completing the course, and assignments completed or in progress. We also collect information about what happens when you use the Website (e.g., page views, length of time on pages, support document searches). We use this information to provide our services to you, as well as get insights on how people use our services, so we can make our services better.

Stored Information
We may access information stored on your mobile device via our mobile app. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access a file on your mobile device, our services may access the files stored on your device.

Online Postings
Certain Personally Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the Website. We may provide areas on the Website where you can post reviews and other information relating to your activities on the Website. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

Company 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 through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though this may not opt you out of all emails, such as notices about your account, including service announcements and administrative messages.

General Use by Company
Company uses the Personally Identifying Information in the file we maintain about you and other information we obtain from your current and past activities on the Website (1) to deliver the products and services you have requested; (2) to manage your account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone, and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies, or other third parties; (4) to develop and display content and advertising tailored to your interests on the Website and other sites; (5) to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud, and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

Company Disclosures
Company will disclose Personally Identifying Information under the following circumstances:

  • By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally Identifying Information in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property, or safety of Company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • Marketing Communications. Unless users opt out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable), or by contacting us using the contact information below.
  • Third-Party Marketing Communications. Unless users opt out from receiving marketing materials upon registration, Company may provide users’ email information to third parties, so those third parties may directly contact them about additional products and services. To cease having your email information provided to third parties, you may do so by going to your account settings (if applicable) or contacting us using the contact information below. Even after opting out, you may continue to receive marketing emails from third parties to whom Company already has provided your email information. You will be responsible for directly contacting such third parties to request cessation of further marketing emails.
  • Third-Party Service Providers. We may share your Personally Identifying Information, which may include your name and contact information (including email address), with our authorized service providers that perform certain services 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 personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
  • Business Transfers; Bankruptcy. Company may disclose all Personally Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally Identifying Information will be subject to this Privacy Policy or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt out of it. Personally Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.
  • Employees, Contractors, and Consultants: Some Company employees and operations contractors, and consultants may have limited access to your Personal Information in the course of providing services to you, including for the purpose of troubleshooting problems and/or resolving complaints. These contractors include vendors and suppliers that provide us with technology, services, and/or content for the operation and maintenance of the Website. Access to your Personal Information is limited to the information reasonably necessary for the employee or contractor to perform the function needed to resolve the issue or to provide or improve the service.
  • Healthcare Operations and Services: We may use and disclose your Personally Identifying Information to provide you with care, to run healthcare operations, to take payment, or to provide information to clinicians who work with our Website, platforms, and systems, and to comply with state and US federal regulations. We implement a range of technical, administrative, and physical safeguards to protect your Personally Identifying Information. To the extent you are transmitting information known as Protected Health Information (“PHI”) under HIPAA, this may entitle you to certain rights described under HIPAA.
  • Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our products and services and we may share a hashed version of your email address to facilitate customized ad campaigns with partners.
  • Published Support Requests: If you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.

Legal Bases for Collecting and Using Information
A note here for those in the European Union (EU) about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

  • The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account, for example, in order to enable access to the Website on your device or charge you for a paid plan; or
  • The use is necessary for compliance with a legal obligation; or
  • The use is necessary in order to protect your vital interests or those of another person; or
  • We have a legitimate interest in using your information, for example: to provide and update our products and services; to improve them so that we can offer you an even better user experience; to safeguard them; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising and better understand user retention and attrition; to monitor and prevent any problems with our products and services; and to personalize your experience; or
  • You have given us your consent, for example before we place certain cookies on your device and access and analyze them later on, as described in our Web Cookie policy.

Your Ability to Change Personally Identifying Information; Account Termination
You may at any time review or change your Personally Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use, and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.

Children’s Personally Identifying Information
The features, programs, promotions, and other aspects of our service requiring the submission of Personally Identifying Information are not intended for anyone under thirteen (13) years of age. We do not knowingly collect Personally Identifying Information from children under the age of 13 other than minor children receiving the service through registration by their parent or legal guardian. If you are under 13, then you may not use or access our website or services at any time or in any manner. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed Personally Identifying Information to us, please contact us at Support@EFTuniverse.com. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s Personally Identifying Information as well as prohibit the use thereof.

Policies and Practices of Company’s Affiliates
Through Company and the Website you may be introduced to a variety of other party vendors and sites including but not limited to vendors of goods and services, providers of other information, and other such parties, called “affiliates.” Any links to such other vendors and sites are provided solely as a convenience and our Terms of Use shall govern all such links.

The privacy policies and terms and conditions of service of these other parties are not under Company’s control and may differ from Company’s privacy policy and terms and conditions of service. You should read the privacy policies and terms and conditions of service of those vendors carefully. The use of any information you may provide to any other party, or the use of “cookie” technology by any other party, will be governed by the privacy policy and terms and conditions of service of the operator of the other site that you are visiting.

In some cases, these other parties may share the information they collect about you with Company. If you have any doubts about the privacy or security of the information you are providing on another site or about their privacy policy and terms and conditions of service, Company recommends that you contact that site directly for more information and review their privacy policy and terms and conditions of service.

Company is not now and never will be responsible for the actions of such other parties in any manner whatsoever, including but not limited to any violation of such privacy policies, terms and conditions of service, or otherwise. As an Amazon Associate, Company receives affiliate fees from qualifying purchases.

If you offer our ecommerce services to sell our products or services to others through our site, you have the option to create an affiliate account or log into an existing account. As an affiliate, you will typically provide us with information about your financial account for commission payments, such as the email address for your PayPal account and your TaxID/SSN for accounting purposes.

DATA PROTECTION AND GDPR COMPLIANCE

  • Data protection principles: The Company is committed to processing data in accordance with its responsibilities under the European General Data Protection Regulation (GDPR). Article 5 of the GDPR requires that personal data shall be: “processed lawfully, fairly and in a transparent manner in relation to the data subject [any living individual whose personal data are collected, held or processed by the Company]; collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes; adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject; and processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”
  • Scope/General provisions: The GDPR’s requirements apply to all personal data processed by the Company and to anyone in the Company who processes that data. The data protection officer (DPO) shall take responsibility for the Company’s ongoing compliance with this policy. This policy shall be reviewed at least annually. For the purposes of GDPR, Company fits the definition of a small and medium-sized enterprise (SME) and data processing is not done regularly, does not affect the rights or freedoms of the individuals involved, and does not deal with sensitive data or criminal records.
  • Lawful, fair, and transparent processing: Personal data shall be processed lawfully, fairly, and transparently in relation to the data subject. To ensure that the processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems. The Register of Systems shall be reviewed at least annually. Individuals shall have the right to ask what information the Company holds about them and why, how to gain access to the information, be informed on how to keep it up to date, and be informed on how the Company is meeting its data protection obligations. Individuals have the right to access their personal data, and any such requests made to the Company shall be dealt with in a timely manner. The Company at its discretion may charge individuals up to $20 USD per request and will provide all relevant data within (twenty) 20 business days. The Company will always verify the identity of anyone making a personal data request before handing over any information. In certain circumstances, personal data may be requested to be disclosed to law enforcement agencies without the consent of the data subject. For more information regarding personal data request from law enforcement agencies, please see the Company’s Legal Release policy above (“By Law or to Protect Rights”).
  • Lawful purposes: All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task, or legitimate interests. The Company shall note the appropriate lawful basis in the Register of Systems. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
  • Data security and minimization: The Company shall ensure that personal data are stored securely using modern software that is kept-up-to-date. Access to personal data shall be limited to personnel who need access and appropriate security shall be in place to avoid unauthorized sharing of information. The Company shall ensure that all employees keep all data secure, by taking sensible precautions and following the following guidelines. Appropriate back-up and disaster recovery solutions shall be in place. Strong passwords must be used, and they should not be shared for non-system administrative functions. In the event that a system administrative function requires a single user account and password, such as a root password on a web server, the account and password will be strictly controlled by a restricted set of administrators, no more than necessary to adequately support the business needs. Personal data are not to be disclosed to unauthorized people, either within the Company or externally. The Company should avoid saving personal data directly on laptops or other mobile devices like tablets or smartphones. If there is a need to transfer personal data to a laptop or mobile device for a very specific business need (e.g. exchanging hotel registration information between the event and hotel staff, providing user name tags and rooming lists, etc.), the user will be notified and required to provide explicit consent to the transfer of data on their behalf, as well as the data will be immediately removed from the computing device by the event staff once the data is no longer required to support the business transactions. All servers and computers containing data should be protected by approved security software and a firewall. Personal data must be encrypted before being transferred electronically. The Company shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. The Company will provide training to all employees to help them understand their responsibilities in handling data. The Company shall ensure that only people able to access data covered by this policy should be those who need it for their work. The Company shall ensure that data is not shared informally. When access to confidential information is required, employees will follow strict processes in validating consent from the customer.
  • Accuracy: The Company shall take reasonable steps to ensure personal data are accurate. Where necessary for the lawful basis on which data are processed, steps shall be put in place to ensure that personal data are kept up to date. Data will be held in as few places as necessary. The Company should not create unnecessary additional data sets. The Company should take every opportunity to ensure that data are updated. For example, by confirming customers’ details when they call. The Company will make it easy for customers to update the information held about them, for instance, via the company website. Once inaccuracies are discovered, data should be updated. For instance, if a customer can no longer be reached on the telephone number stored in the database, it should be removed.
  • Archiving/removal: To ensure that personal data are kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data are processed and review this process annually. The archiving policy shall consider what data should/must be retained, for how long, and why. When personal data are deleted, this shall be done safely such that the data are irrecoverable.
  • Breach: In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data, the Company shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the supervisory authorities. In addition, if the breach is likely to result in a “high risk to the rights and freedoms” of the individual, the Company shall complete a Data Breach Notification Form to data subjects. The Company shall maintain an internal record of all personal data breaches in a Data Breach Register detailing the facts surrounding the breach, the effects of the breach, and any remedial action taken.

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY

Company contractually prohibits its contractors, affiliates, vendors, and suppliers from disclosing Personally Identifying Information received from Company, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally Identifying Information that users provide directly to those third parties or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets, and a variety of other third-party applications accessible through the Website.

Company neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website, or otherwise, and before providing any Personally Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.

HOW LONG WE KEEP INFORMATION

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it, as described above, and we are not legally required to continue to keep it.

For example, we keep the web server logs that record information about a visitor to the Website such as the visitor’s IP address, browser type, and operating system, for approximately 120 days. We retain the logs for this period of time in order to, among other things, analyze traffic to the Website and investigate issues if something goes wrong.

As another example, we will retain information up to 120 days after a live event in the event there is a customer service or support question related to who attended, arrival date, and departure date.

SECURITY

We use reasonable electronic, personnel, and physical measures to protect Personally Identifiable Information from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.

We are dedicated to protecting all information on the Website, as is necessary. However, you are responsible for maintaining the confidentiality of your Personally Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

Despite our efforts to protect your Personally Identifiable Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted. We do not utilize encryption systems for emails from us to you. Therefore, we make no representations or warranties regarding the sufficiency of the above security measures. No data transmission over the Internet or through mobile devices can be guaranteed to be 100% secure.

While we strive to protect your personal information from unauthorized access, use, or disclosure, we cannot ensure or warrant the security of any information you transmit to us on the Website. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Therefore, the Company is not responsible for any actual or consequential damages that result from a lapse in compliance with this Privacy Policy because of a security breach or technical malfunction.

CHOICES REGARDING YOUR INFORMATION
You have several choices available when it comes to information about you:

  • Limit the Information You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our products and services (for example, automatic notifications and updates) may not be accessible.
  • Limit Access to Information on Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features (like adding a location to a photograph, for example).
  • Opt Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
  • Set Your Browser to Reject Cookies: You can usually choose to set your browser to remove or reject browser cookies before using the Website, with the drawback that certain features of the Website may not function properly without the aid of cookies.
  • Close Your Account: While we’d be very sad to see you go, if you no longer want to be part of our community, you can close any or all of your accounts with us. Please keep in mind that we may continue to retain your information after closing your account, as described in “How Long We Keep Information” above, for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests and tax obligations or reasonably needed for our legitimate business interests.

YOUR RIGHTS

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (GDPR), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the right to:

  • Know how we are using your data;
  • Request access to your personal data;
  • Request correction or deletion of your personal data;
  • Object to our use and processing of your personal data;
  • Request that we limit our use and processing of your personal data;
  • Request portability of your personal data; and
  • Request review of automated decision-making including profiling.

You can usually access, correct, or delete your personal data using your account settings and tools we offer, but if you aren’t able to do that or you would like to inquire about one of the other rights, contact us. EU citizens also have the right to make a complaint to a government supervisory authority.

TRANSFERRING INFORMATION

Because our products and services are offered worldwide, the information about you that we process when you use the services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, business partners, or contractors. This is required for the purposes listed above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

  • In the case of US based entities, entering into European Commission approved standard contractual arrangements with them; or
  • In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them. You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

PRIVACY POLICY CHANGES

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the end of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

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, at least once a year and free of charge, information about the Personally Identifying 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 the Personally Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally Identifying 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 our privacy officer as listed below.

DO-NOT-TRACK POLICY

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. The Website does currently respond to DNT browser signals or mechanisms.

THIS PRIVACY POLICY AGREEMENT

This agreement shall be subject to and interpreted under the laws of the state of California applicable to agreements wholly to be performed therein as well as the laws of the United States, where applicable. Captions are for clarity sake only and have no substantive effect. This agreement is the complete understanding between you and Company except that Company may change the provisions of this agreement by posting such changes on the Website but without any individual notice to you and if you use the Website after such change is so posted, you will be deemed to have accepted such change and such change shall be retroactively made a part of this agreement.

This agreement shall bind and benefit each of your and Company’s respective heirs, assigns, and successors in interest, but any restrictions on assignment and transfer otherwise contained in this agreement shall otherwise apply. A waiver of any provision of this agreement, or any claimed breach thereof, shall not be deemed a waiver of any other provision or breach. All remedies provided Company in this agreement are cumulative and the exercise by Company of any remedy shall be without prejudice to Company’s exercise of any other rights or remedies available to Company.

Any dispute arising under this agreement shall be determined only by a court of competent jurisdiction only in Sonoma County, California, and Company shall be entitled to injunctive relief. You expressly consent to personal jurisdiction in such state and in such court and you expressly waive the right to a jury trial. In any action under this agreement, the prevailing party shall be entitled to attorneys’ fees and court costs. In the event any portion of this agreement shall be held invalid or unenforceable, it shall not affect the validity or enforceability of the rest of this agreement. All of the provisions of this agreement shall survive the termination of this agreement for any reason.

QUESTIONS OR COMPLAINTS

If you have any questions regarding our Privacy Policy or complaints regarding your privacy rights, please submit your complaint in writing to our Privacy Officer at:

Energy Psychology Group, Inc.
Attn: Privacy Officer
PO Box 222
Petaluma, CA 94953-0222

Email: Support@EFTuniverse.com
Phone: (707) 525-9292

We will not retaliate against you for filing a complaint.

In addition, you can complain to:

Secretary of the U.S. Department of Health and Human Services
Office of Civil Rights
200 Independence Avenue, SW
Room 509F, HHH Building
Washington, DC 20201

For additional information, call U.S Office of Civil Rights at (800) 368-1019 (Voice) or (800) 537-7697 or via fax: (202) 619-3818 or email: ocrmail@hhs.gov, or contact your local Office of Civil Rights of the U.S. Department of Health and Human Services: https://www.hhs.gov/ocr/about-us/contact-us/index.html#ocr-regional-offices.

EFFECTIVE DATE

This Privacy Policy is effective as of August 1, 2021, and was last updated on August 1, 2021.

CHANGES TO THIS NOTICE

If we change the terms of this Privacy Policy, then we will post the new Privacy Policy on our Website. Any new Privacy Policy will apply to all the information that we maintain, including information that was created prior to the change.

IF YOU DO NOT AGREE WITH AND ACCEPT ALL OF THE FOREGOING PROVISIONS, DO NOT REMAIN ON THE WEBSITE AND DO NOT SUBSCRIBE TO COMPANY’S EMAIL LIST.

California Consumer Privacy Act of 2018 Link to: https://oag.ca.gov/privacy/ccpa