[[Â Privacy Policy ]]
Effective date: [[Â February 18, 2025Â ]]
 This Privacy Policy applies to the website `www.InnateWisdomCourses.com` (the "Site"), owned and operated by Dan Fleishman ("we," "us," or "our"). Dan Fleishman is the data controller and can be contacted at:
- **Email:** `[email protected]`
- **Phone:** `(888) 281-0841`
- **Address:** 35876 Winchester Road, Unit 300-103, Winchester, CA 92596, USA
This Privacy Policy outlines how we collect, use, disclose, and protect your personal data when you visit or use our Site, which operates as an e-commerce platform offering educational webinars and courses related to chiropractic care. This policy applies in addition to our Terms and Conditions.
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## Purpose
The purpose of this Privacy Policy is to inform users of our Site about:
1. The personal data we collect;
2. How we use collected data;
3. Who has access to the data collected;
4. The rights of Site users under applicable laws (e.g., GDPR, CCPA, etc.);
5. Our cookie policy; and
6. How we ensure compliance with global privacy regulations.
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## Global Legal Compliance
We are committed to complying with applicable data protection laws worldwide, including but not limited to:
- **General Data Protection Regulation (GDPR):** For users in the European Union (EU), we adhere to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
- **UK Data Protection Act 2018:** For users in the United Kingdom, we adhere to the GDPR as enshrined in the UK Data Protection Act 2018.
- **California Consumer Privacy Act (CCPA):** For residents of California, we comply with the CCPA (California Civil Code § 1798.100 et seq.), as amended by the California Privacy Rights Act (CPRA).
- **Personal Information Protection and Electronic Documents Act (PIPEDA):** For users in Canada, we adhere to PIPEDA.
- **Act on the Protection of Personal Information (APPI):** For users in Japan, we comply with APPI.
If you are located outside these jurisdictions, we will apply equivalent protections consistent with internationally recognized standards (e.g., OECD Privacy Guidelines).
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## Consent
By using our Site, you consent to:
1. The conditions set out in this Privacy Policy; and
2. The collection, use, and processing of your personal data as described herein.
You may withdraw your consent at any time by contacting us at `[email protected]`. Withdrawing consent will not affect the lawfulness of processing based on consent before withdrawal. If you are in the EU, UK, or California, you have the right to withdraw consent without detriment, and we will inform you of the consequences of withdrawal.
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## Legal Basis for Processing (GDPR/UK DPA)
We collect and process personal data about users in the EU and UK only when we have a legal basis under Article 6 of the GDPR. The legal bases we rely on include:
1. **Consent:** You have provided consent for one or more specific purposes (e.g., subscribing to our newsletter or webinar).
2. **Contractual Necessity:** Processing is necessary for the performance of a contract with you (e.g., processing payments for courses).
3. **Legitimate Interests:** Processing is necessary for our legitimate interests (e.g., improving our Site or conducting analytics), provided your interests or fundamental rights do not override these interests.
4. **Legal Obligation:** Processing is necessary to comply with a legal obligation (e.g., tax reporting).
For users in other jurisdictions, we apply equivalent legal bases under local laws (e.g., CCPA’s “business purpose” for California residents).
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## Personal Data We Collect
We only collect data that helps us achieve the purposes outlined in this Privacy Policy. We will not collect additional data without notifying you first.
### Data Collected Automatically
When you visit and use our Site, we may automatically collect and store the following information:
- IP address;
- Location (approximate, based on IP);
- Hardware and software details (e.g., browser type, device type);
- Clicked links and navigation paths;
- Content viewed and pages visited;
- Email address (if provided via cookies or tracking pixels);
- Name (if provided via cookies or tracking pixels).
This data is collected using cookies, web beacons, and similar technologies, as described in our Cookie Policy below.
### Data Collected Non-Automatically
We may also collect the following data when you perform certain functions on our Site:
- First and last name;
- Email address;
- Phone number;
- Payment information (e.g., credit card details, processed via third-party providers);
- Autofill data (e.g., billing address).
This data may be collected through:
- Creating an account;
- Registering for webinars or courses;
- Making purchases;
- Subscribing to newsletters or marketing communications.
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## How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on relevant Site pages. We will not use your data beyond what we disclose here.
### Purposes for Automatic Data:
- **Analytics and Statistics:** To analyze Site usage, improve functionality, and enhance user experience (e.g., via Google Analytics or similar tools).
- **Email Marketing:** To send promotional emails about our webinars, courses, or related offerings, subject to your consent.
### Purposes for Non-Automatic Data:
- **Communication:** To respond to inquiries, provide customer support, or send order confirmations and webinar access details.
- **Transaction Processing:** To process payments, fulfill orders, and manage account-related activities.
- **Personalization:** To tailor content, offers, or recommendations based on your preferences or behavior.
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## Who We Share Personal Data With
We may disclose user data to the following parties:
### Employees
We may share user data with our employees who reasonably need access to achieve the purposes set out in this Privacy Policy. All employees are bound by strict confidentiality agreements, and breaches may result in termination.
### Third Parties
We may share user data with the following third parties for the specified purposes:
- **Payment Processors (e.g., Credit Card Processors):** To process transactions (e.g., Stripe, PayPal). We share credit card information only as necessary for payment processing, and third parties are prohibited from using this data for other purposes.
- **Analytics Providers (e.g., Google Analytics):** To analyze Site usage and improve our services. We share anonymized or aggregated data (e.g., IP addresses, click patterns) and ensure compliance with data minimization principles.
- **Email Marketing Platforms (e.g., Mailchimp):** To send marketing communications, subject to your consent. We share only necessary data (e.g., email addresses, names).
Third parties will not access user data beyond what is reasonably necessary to achieve the given purpose and must comply with applicable privacy laws (e.g., GDPR, CCPA).
### Other Disclosures
We will not sell or share your data with other third parties except in the following cases:
1. If required by law or legal process (e.g., court orders, subpoenas);
2. If necessary for legal proceedings or to protect our legal rights;
3. To buyers or potential buyers of our company in the event of a merger, acquisition, or sale, subject to the buyer agreeing to this Privacy Policy; or
4. With your explicit consent for other purposes not listed here.
If you follow hyperlinks from our Site to another website, we are not responsible for their privacy policies or practices.
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## How Long We Store Personal Data
We store user data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specific retention periods include:
- **Transaction Data:** Up to 7 years for tax and accounting purposes (per U.S. IRS requirements and similar international laws).
- **Marketing Data:** Until you withdraw consent or request deletion, typically no longer than 2 years after your last interaction unless required by law.
- **Analytics Data:** Anonymized or aggregated data may be stored indefinitely for statistical purposes; identifiable data is retained for up to 2 years or until you request deletion.
We will notify you if your data is kept longer than expected and provide options to delete or modify it.
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## How We Protect Your Personal Data
To protect your security, we implement the following measures:
- **Encryption:** We use strong SSL/TLS encryption (e.g., 256-bit) for data transmission and storage.
- **Secure Storage:** All data is stored on secure servers in facilities with physical and digital security measures.
- **Access Control:** Data is accessible only to authorized employees under strict confidentiality agreements. Breaches result in disciplinary action, including termination.
- **Third-Party Security:** We require third-party processors to implement equivalent security measures and enter into data processing agreements (DPAs) compliant with GDPR, CCPA, and other laws.
While we take all reasonable precautions, no method of transmission or storage is 100% secure. We cannot guarantee absolute security but will address any breaches promptly and notify affected users as required by law (e.g., GDPR Article 33, CCPA Section 1798.150).
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## International Data Transfers
We transfer user personal data to the following countries:
- **United States of America:** Our primary data storage and processing location.
For users in the EU, UK, or other regions with strict data transfer laws, we ensure compliance by:
1. Transferring data only to countries deemed to have adequate data protection by the European Commission, UK adequacy regulations, or equivalent authorities (e.g., U.S. companies certified under the EU-U.S. Data Privacy Framework, if applicable); or
2. Implementing appropriate safeguards, such as:
- Standard Contractual Clauses (SCCs) approved by the European Commission or UK Information Commissioner’s Office (ICO);
- Binding Corporate Rules (BCRs) for intra-organizational transfers; or
- Other mechanisms ensuring equivalent protection (e.g., encryption, DPAs).
You can request details of specific safeguards by contacting our Data Protection Officer.
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## Your Rights as a User
Under applicable laws, you have the following rights regarding your personal data. To exercise these rights, contact our Data Protection Officer (see “Contact Information” below):
### GDPR/UK DPA Rights (EU/UK Users):
1. **Right to be Informed:** You have the right to know how we collect and use your data (as outlined in this Policy).
2. **Right of Access:** You can request a copy of your personal data we hold.
3. **Right to Rectification:** You can request corrections to inaccurate or incomplete data.
4. **Right to Erasure (“Right to be Forgotten”):** You can request deletion of your data, subject to legal retention requirements.
5. **Right to Restrict Processing:** You can request we limit how we process your data (e.g., during a dispute or investigation).
6. **Right to Data Portability:** You can request your data in a structured, machine-readable format for transfer to another controller.
7. **Right to Object:** You can object to processing based on legitimate interests or for direct marketing purposes.
8. **Right to Withdraw Consent:** You can withdraw consent at any time (see “Consent” section).
### CCPA Rights (California Residents):
1. **Right to Know:** You can request information about the personal data we collect, use, disclose, or sell.
2. **Right to Delete:** You can request deletion of your personal data, subject to exceptions (e.g., legal obligations).
3. **Right to Opt-Out of Sale:** We do not sell personal data, but if this changes, you can opt out (see “Do Not Sell My Personal Information” below).
4. **Right to Non-Discrimination:** We will not discriminate against you for exercising your CCPA rights (e.g., no price or service differences).
### Other Jurisdictions:
Users in Canada (PIPEDA), Japan (APPI), or other regions have equivalent rights under local laws. Contact us for specific details.
We will respond to valid requests within 30 days (or as required by law, e.g., GDPR’s one-month timeframe, extendable by two months if complex). We may require verification of your identity before processing requests.
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## Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn we have collected such data, we will delete it promptly. If a child under 16 has provided personal data, their parent or guardian may contact our Data Protection Officer to request deletion or access.
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## How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used it, who we have disclosed it to, or if you want your data deleted, modified, or to exercise any other rights, please contact our Data Protection Officer:
- **Name:** Dan Fleishman
- **Email:** `[email protected]`
- **Phone:** `(888) 281-0841`
- **Address:** 35876 Winchester Road, Unit 300-103, Winchester, CA 92596, USA
We may charge a reasonable fee for excessive or repetitive requests, as permitted by law (e.g., GDPR Article 15).
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## Do Not Sell My Personal Information (CCPA)
We do not sell personal data as defined by the CCPA. If this changes, we will update this Policy, notify users, and provide an opt-out mechanism (e.g., a “Do Not Sell My Personal Information” link).
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## Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference you can set in certain web browsers. We do not track users over time and across third-party websites, so we do not respond to browser-initiated DNT signals. However, third parties (e.g., analytics providers) may collect data subject to their own policies. We are not responsible for their practices but require them to respect DNT where feasible.
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## How to Opt-Out of Data Collection, Use, or Disclosure
In addition to the methods above, you can opt out as follows:
1. **Marketing Emails:** Click “unsubscribe” at the bottom of any marketing email or update your preferences in your account settings.
2. **Cookies:** Disable cookies in your browser (see “Cookie Policy” below), though this may affect Site functionality.
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## Cookie Policy
A cookie is a small file stored on your device by our Site to collect data about your browsing habits. You can manage cookies via your browser settings:
- **Notification:** Choose to be notified each time a cookie is transmitted.
- **Disable Cookies:** Disable cookies entirely, though this may reduce Site functionality.
We use the following types of cookies:
1. **Functional Cookies:** To remember your preferences (e.g., language, login status) and improve user experience.
2. **Analytical Cookies:** To analyze Site usage (e.g., pages visited, time spent) and improve design (e.g., via Google Analytics).
3. **Targeting Cookies:** To personalize content and tailor advertisements based on your interests.
4. **Third-Party Cookies:** Set by external providers (e.g., marketing or analytics platforms) to monitor preferences or deliver targeted ads. We require third parties to comply with this Privacy Policy and applicable laws.
For a list of specific cookies, contact our Data Protection Officer. You can withdraw consent for non-essential cookies at any time via your browser settings or by contacting us.
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## Modifications
We may amend this Privacy Policy to maintain compliance with laws or reflect changes in our data practices. Updates will be indicated by revising the “Last Updated” date. We recommend reviewing this Policy periodically. If significant changes occur, we may notify users via email or a prominent notice on our Site.
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## Complaints
If you have concerns about how we process your personal data, contact our Data Protection Officer first at `[email protected]`. We will resolve issues where possible. If unsatisfied, you may:
- **EU/UK Users:** Lodge a complaint with your local supervisory authority (e.g., Data Protection Authority in your country) or the European Data Protection Supervisor.
- **California Residents:** File a complaint with the California Attorney General’s Office or the California Privacy Protection Agency.
- **Other Regions:** Contact your local data protection authority (e.g., Office of the Privacy Commissioner of Canada for PIPEDA, Personal Information Protection Commission for APPI).
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## Contact Information
For questions, concerns, or complaints, contact our Data Protection Officer:
- **Name:** Dan Fleischman
- **Email:** `[email protected]`
- **Phone:** `(888) 281-0841`
- **Address:** 35876 Winchester Road, Unit 300-103, Winchester, CA 92596, USA
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### Additional Notes for Global Compliance:
- **Language Simplicity:** The policy is written in clear, plain language to meet GDPR’s transparency requirements and accessibility standards.
- **Data Minimization:** We emphasize collecting only necessary data, aligning with GDPR, CCPA, and other laws.
- **Cross-Border Transfers:** The policy includes safeguards for international data transfers, ensuring compliance with GDPR’s SCCs, UK adequacy regulations, and CCPA’s requirements for data exported from California.
- **Children’s Privacy:** Strengthened to comply with COPPA (U.S.) and GDPR’s age restrictions (under 16).
- **CCPA-Specific Elements:** Added “Do Not Sell My Personal Information” and non-discrimination assurances for California residents.
This Privacy Policy is now robust, clear, and compliant with global standards. If you need help implementing it on your Site or have specific jurisdictional concerns, let me know, and I can refine further!
