Table of Contents
What personal information do we collect from the people that visit our blog, website or app?
When ordering, or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, credit card information or other details to help you with your experience.
During registration, a user is required to give certain information (such as name and email address). This information is used to contact you about the products/services on our site in which you have expressed interest. At your option, you may also provide demographic information (such as gender or age) about yourself, but it is not required.
When do we collect information?
We collect information from you when you register on our site, place an order, subscribe to a newsletter, fill out a form to download information or enter comments or information on our site.
How do we treat information received through orders?
We request information from you on our order form. To buy from us, you must provide contact information (such as name and shipping address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fill your orders. If we have trouble processing an order, we’ll use this information to contact you.
How do we treat surveys and contests?
From time-to-time our site requests information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, navigate our website, or use certain other site features in the following ways:
- To respond to you regarding the reason you contacted us.
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To improve our website in order to better serve you.
- To allow us to better service you in responding to your customer service requests.
- To administer a contest, promotion, survey or other site feature.
- To quickly process your transactions.
- To send periodic emails regarding your order or other news, products and services.
How can you access and control your information?
You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website:
- See what data we have about you, if any.
- Change/correct any data we have about you.
- Have us delete any data we have about you.
- Express any concern you have about our use of your data.
- Have your personal data transmitted directly from us to another controller, when technically feasible.
How do we protect your information?
- We take stringent precautions to protect your information. When you submit your information via the website, your information is protected both online and offline.
- Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
- We use regular Malware Scanning.
- Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
- We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
- All transactions are processed through a gateway provider and are not stored or processed on our servers.
Do we use ‘cookies’?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information.
- Help remember and process the items in the shopping cart.
- Auto-complete forms.
- Understand and save user’s preferences for future visits.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If users disable cookies in their browser:
If you turn cookies off, some features will be disabled. Some of the features that make your site experience more efficient and may not function properly, like auto form completion. However, you will still be able to place orders.
We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you.
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We will only release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.
This website contains links to other sites for informational purposes only. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously.
- Via email as necessary for compliance
You can change your personal information:
- By emailing us
- By phoning us
- By clicking on “Update your email preferences” in the footer of our emails to you
How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioral tracking.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
In order to be in-line with the GDPR regulations (listed below) and the Fair Information Practices, we will notify you via email within 72 hours.
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
- Process orders and to send information and updates pertaining to orders.
- Send you additional information related to your product and/or service
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can:
- Follow the “Unsubscribe” instructions at the bottom of each email
- and we will promptly remove you from ALL correspondence
The General Data Protection Regulation 2016 (GDPR)
The General Data Protection Regulation 2016 (GDPR) replaces the EU Data Protection Directive of 1995 and supersedes the laws of individual Member States that were developed in compliance with the Data Protection Directive 95/46/EC.
Being First, Inc. is committed to compliance in respect of personal data, and the protection of the “rights and freedoms” of individuals whose information Being First collects and processes in accordance with the General Data Protection Regulation (GDPR). Compliance with the GDPR is described by this policy and other relevant company policies, along with connected processes and procedures. Partners and any third parties working with or for Being First, and who have or may have access to personal data, will be expected to have read, understood and to comply with this policy. All staff in managerial or supervisory roles throughout Being First are responsible for developing and encouraging good information handling practices within Being First.
Generally, Being First is a data controller under the GDPR as it relates to the personal data of training and coaching attendees. Our relevant legal basis for controlling (and occasionally) processing this data is that it is necessary for the performance of a contract with the individual and their employer. By way of example, Being First uses this data to communicate licensing deadlines, provide the details of upcoming events, share relevant industry information and to maintain a record of coaching and training. Being First will only collect and maintain data that is necessary to fulfill its contractual obligations and store such data only for so long as is necessary.
Generally, Being First uses HubSpot, Inc. as it’s data processors, under the GDPR as it relates to the personal data of training and coaching attendees. The HubSpot Data Processing Agreement (“DPA”), that includes the Standard Contractual Clauses adopted by the European Commission, as applicable, reflects the parties’ agreement with respect to the terms governing the Processing of Personal Data under the HubSpot Customer Terms of Service (the “Agreement”) can be found directly on their website here.
HubSpot’s certification under the new EU-US Privacy Shield framework, a program for the transfer of data from the EU to the US, has now been confirmed by the US Department of Commerce. See their official listing here.
Being First is committed to the security of its data and has established a process for continuous auditing to ensure this security. Being First will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, implementing technical and organizational measures, as well as adopting techniques such as data protection by design, DPIAs, breach notification procedures and incident response plans.
All policies established regarding data protection and GDPR shall be reviewed on an ongoing basis to ensure compliance with best practice and regulation. Questions relating to this policy or its implementation can be directed to [email protected].
If you would like to receive a copy of the information we collect, you may request a copy by contacting us at [email protected].