Fulfilled Life Design, Inc.
May 25, 2018
Fulfilled Life Design, Inc. understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
“Our Site” means this website, transformyourbrilliance.com;
“United States of America and EU Cookie Law” means the relevant parts of applicable laws in the United States of America and the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;
“We/Us/Our” means Fulfilled Life Design, Inc., of PO Box 36198, Indianapolis, Indiana, 46236, USA.
2. Information About Us
2.1 Our Site, transformyourbrilliance.com, is owned and operated by Fulfilled Life Design, Inc., of PO Box 36198, Indianapolis, Indiana, 46236, USA.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.2 Business/company name
4.3 Job title;
4.5 Contact information such as email addresses and telephone numbers;
4.6 Demographic information such as post code, preferences and interests;
4.7 Financial information such as credit / debit card numbers;
4.8 Anonymized IP address (automatically collected);
4.9 Web browser type and version (automatically collected);
4.10 Operating system (automatically collected);
4.11 A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with applicable laws in the United States of America and the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible products and services to you. This includes:
5.2.1 Providing and managing your Account;
5.2.2 Providing and managing your access to Our Site;
5.2.3 Personalising and tailoring your experience on Our Site;
5.2.4 Supplying Our products and services to you;
5.2.5 Personalising and tailoring Our products and services for you;
5.2.6 Responding to communications from you;
5.2.7 Supplying you with email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the bottom of any email);
5.2.8 Market research;
5.2.9 Analysing your use of Our Site [and gathering feedback] to enable Us to continually improve Our Site and your user experience;
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR postal mail with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under applicable laws in the United States of America and the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015. Any phone calls and/or text messages delivered to your phone or device may cause you to incur extra data, text messaging, or other charges from your wireless carrier. Message and data rates may apply. You are solely responsible for any carrier charges incurred as a result of phone and/or text communications from Fulfilled Life Design, Inc. or TransformYourBrilliance.com.
5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) Processing is necessary for compliance with a legal obligation to which we are subject;
d) Processing is necessary to protect the vital interests of you or of another natural person;
e) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personally identifiable information. For more information on protecting your privacy, please visit www.ftc.gov/privacy.
6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that we cannot guarantee that your personally identifiable information will be completely free from unauthorized access by third parties such as hackers and your use of our Service demonstrates your assumption of this risk. You are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. Data will only be shared and used within the bounds of the law.
7.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
9. How Can You Control Your Data?
9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
9.2 You should be aware that personally identifiable information which you voluntarily include and transmit online on the Service or in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum such as an in-person panel or survey, may be viewed and used by others without any restrictions. We are unable to control such uses of your personally identifiable information, and by using the Service or any other online services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties for any number of purposes.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 14.
12. What Cookies Do We Use and What For?
12.2 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.3 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.4 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1 The right to request access to, deletion of or correction of, your personal data held by Us;
13.2 The right to complain to a supervisory authority;
13.3 The right to be informed of what data processing is taking place;
13.4 The right to restrict processing;
13.5 The right to data portability;
13.6 The right to object to processing of your personal data;
13.7 Rights with respect to automated decision-making and profiling (see section 14 below).
14. Automated Decision-Making and Profiling
14.1 We do not currently use personal data for the purposes of automated decision-making and profiling. If We choose to use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorized by law; or
c) You have given you explicit consent.
14.3 Where We use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
15. Contacting Us