The Empowerment Agency website and blog is owned and managed by The Empowerment Agency (TEA), LLC. TEA makes every reasonable effort to keep your personal information protected and private. We do not share personal information collected unless prior authorization is given.
BY USING ANY OF OUR SITES YOU CONSENT TO THE TERMS OF THIS POLICY AND TO TEA’S COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY PLEASE DO NOT USE THE SITES.
We generally collect three types of information from users of the TEA’S sites: 1) Personal Information (your name, email address, career demographics such as title, interest, licensure etc; payment information); 2) Non-Personal Information (e.g. cookies or IP address); and 3) Personal information related to behavioral health and medical data collected via electronic health record to gather information for clinical assessments. All clinical information is protected by HIPAA and PHI standards and confidentiality.
Non medical/behavioral health) “Personal Information” is defined as information that identifies you personally, such as your name, address, phone numbers, or email address. TEA collects and stores the Personal Information that you have provided to us. Here are some examples of manners in which we may collect your Personal Information on the Sites:
1. A name and an email address so we can deliver our newsletter to you – you would be affirmatively consenting to this by providing this to us in our contact forms.
2. Billing information including name, address and credit card information so that we can process payment to deliver our products or services to you under our contractual obligation.
3. A name and an email address if you complete our contact form with a question. We may send you marketing emails with either your consent or if we believe we have a legitimate interest to contact you based on your contact or question.
Please note that the information above (“Personal Data”) that you are giving to us is voluntarily, and by you providing this information to us you are giving consent for us to use, collect and process this Personal Data. You are welcome to opt-out or request for us to delete your Personal Data at any point by contacting us.
If you choose not to provide us with certain Personal Data, you may not be able to participate in certain aspects of our Website or content.
Retention and Deletion
We retain your Personal Data for the minimum amount of time necessary to provide you with the information and/or services that you requested from us. We may include certain Personal Data for longer periods of time if necessary for legal, contractual and accounting obligations.
Full information about TEA use of your behavioral health and medical information
TEA follows Health Insurance Portability and Accountability Act (HIPAA) of 1996. All Public Health Information (PHI) is protected by confidentiality including software used to communicate and collect information such as HIPAA compliant electronic health record, email, and/or computer encryption services.
Anonymous Data Collection and Use
To maintain our Website’s high quality, we may use your IP address to help diagnose problems with our server and to administer the Website by identifying which areas of the Website are most heavily used, and to display content according to your preferences. Your IP address is the number assigned to computers connected to the Internet. This is essentially “traffic data” which cannot personally identify you, but is helpful to us for marketing purposes and for improving our services. Traffic data collection does not follow a user’s activities on any other websites in any way. Anonymous traffic data may also be shared with business partners and advertisers on an aggregate basis.
“Non-Personal Information” can be technical information or it can be demographic information, such as your age, gender, ZIP code or other geolocation data, or interests. Non-Personal Information does NOT identify you personally. Here are some examples of the Non-Personal Information that is collected via the Sites and a description of how this information is used:
Internet Protocol (IP) address — Your IP address is a number that lets computers attached to the Internet know where to send you data — such as the webpages you view. We use this information to deliver our webpages to you upon request, to tailor our Sites to the interests of our users and to measure traffic within our Sites.
Cookies are text files sent by Web servers to Web browsers and are stored on the user’s computer or mobile device. If the browser is loading a page and the server requests the information stored in the cookie, the cookie is sent back to the server.
Cookies contain data about the user’s activities on the website, and can be used by Web servers to identify and track users as they navigate different pages on a website, and to identify users returning to a website.
Cookies may be either “persistent” or “session” cookies. A persistent cookie will remain valid until its set expiration date (unless deleted by the user). A session cookie will expire at the end of the user session, when the Web browser is closed.
Most browsers allow users to refuse to accept cookies.
· In Google Chrome, you can adjust your cookie permissions by clicking “Options,” “Under the hood” and Content Settings in the “Privacy” section. Click on the Cookies tab in the Content Settings.
· In Safari, you can block cookies by clicking “Preferences,” selecting the “Privacy” tab and “Block cookies.”
· In Internet Explorer, you can refuse all cookies by clicking “Tools,” “Internet Options,” “Privacy,” and selecting “Block all cookies” using the sliding selector.
· In Firefox, you can block all cookies by clicking “Tools,” “Options,” and un-checking “Accept cookies from sites” in the “Privacy” box.
· Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you may not be able to log on, access content or use search functions, for example.
Users can also delete cookies already stored on their computers:
· In Google Chrome, you can adjust your cookie permissions by clicking “Options,” “Under the hood,” and Content Settings in the “Privacy” section. Click on the Cookies tab in the Content Settings.
· In Safari, you can delete cookies by clicking “Preferences,” selecting the “Privacy” tab and selecting “Remove All Website Data.”
· In Internet Explorer, you must manually delete cookie files.
· In Firefox, you can delete cookies by first ensuring that cookies are to be deleted when you “clear private data” (this setting can be changed by clicking “Tools,” “Options” and “Settings” in the “Private Data” box) and then clicking “Clear private data” in the “Tools” menu.
· Doing this may have a negative impact on the usability of many websites.
Use of Information Collected Via the Sites
We use your Personal Information that we collect on the Sites primarily for the following purposes:
· To deliver services, such as educational programs, information or newsletters you request or purchase;
· To let you know about updated information and other new services from TEA or other third parties or to forward promotional materials;
· To process your order and, if necessary, to contact you regarding the status of your order;
· To fulfill the terms of a promotion;
· To ensure the Sites are relevant to your needs;
· To help us create and publish content most relevant to you;
· To contact you regarding additional services and features;
· To request your feedback about your experience with TEA;
· To notify you about a material change to this Policy, if necessary; and
· To allow you access to limited-entry areas of the Sites.
· Non-Personal Information is used as described above and in other ways as permitted by applicable laws, including combining Non-Personal Information with Personal Information.
· Release of Information to Third Parties
· By using the Sites you grant TEA the right to use your Non-Personal Information for marketing and to improve the Sites. This use may involve the disclosure of your Non-Personal Information to third parties. TEA will not share or disclose your Personal Information with third parties.
Third Party Websites and Advertisers
The TEA may also permit advertisers, third party ad networks or other advertising companies to serve advertisements on the Sites. Please be advised that such advertising companies may gather information about your visit to the Sites or other sites (such as through cookies, Web beacons and other technologies) to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which Web pages you were viewing when such ads were delivered. PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH ADVERTISING COMPANIES.
We communicate with our members on a regular basis via email. For example, we may use your email address to confirm your request, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, members cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional.
However, we provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communications from us, such as messages or updates from us regarding new services and products offered on the Sites. For emails, you may opt-out by clicking on the “unsubscribe” link within the text of an email. We will process your request to unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed. Please note that electing to opt-out of our promotional emails does not mean that we will delete or remove your email address from our systems.
TEA reserves the right to make changes to this Policy at any time and for any reason without prior notice. Any changes to this Policy will be posted on this page so that you are always aware of our current policies. We may also contact you by email with changes. Additionally, we will update the “last updated” date below.
No data transmissions over the Internet can be guaranteed to be 100 percent secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to TEA is done at your own risk. However, TEA uses website security measures consistent with current best practices to protect the Sites, email and mailing lists. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorized access or disclosure, loss, alteration or destruction.
PLEASE NOTE THAT THE SITES DO NOT USE SSL ENCRYPTION. THE SITES DO NOT PROCESS PURCHASES. THE SITES USE THIRD PARTY VENDORS (such as, PayPal, Square, etc.) TO PROCESS PURCHASES. User and purchaser information is a high priority and we use our own protective measures, as well as the capabilities of our software and hardware vendors.
We realize there can be incidents of misuse or unauthorized program incursions, as almost every website, service and user encounters. In those instances, our goals are to move quickly to isolate the problem, ensure or restore proper functionality and minimize any inconvenience to our users. As appropriate and necessary, TEA will notify the relevant authorities of these incidents of misuse or unauthorized program incursions of the TEA Sites.
In the event that all or part of TEA’s assets are sold or acquired by another party, or in the event of a merger, you grant TEA the right to assign the Personal and Non-Personal Information collected via the Sites.
What We Do With Information We Collect
We may contact you with information that you provide to us based on these lawful grounds for processing:
1. Consent. We may contact you if you give us your clear, unambiguous, affirmative consent to contact you.
2. Contract. We will contact you under our contractual obligation to deliver goods or services you purchase from us.
3. Legitimate Interest. We may contact you if we feel you have a legitimate interest in hearing from us. For example, if you sign up for a webinar, we may send you marketing emails based on the content of that webinar. You will always have the option to opt out of any of our emails.
We will use the Personal Data you give to us in order to process your payment for the purchase of goods or services under a contract. We only use third party payment processors that take the utmost care in securing data and comply with the GDPR.
Targeted Social Media Advertisements
We may use the data you provide to us to run social media advertisements and/or create look-alike audiences for advertisements.
Share with Third Parties
We may share your information with trusted third parties such as our newsletter provider in order to contact you via email, our merchant accounts to process payments, and Google / social media accounts in order to run advertisements and our affiliates.
Viewing by Others
Note that whenever you voluntarily make your Personal Data available for viewing by others online through this Website or its content, it may be seen, collected and used by others, and therefore, we cannot be responsible for any unauthorized or improper use of the information that you voluntarily share (i.e., sharing a comment on a blog post, posting in a Facebook group that we manage, sharing details on a group coaching call, etc.).
Submission, Storage, Sharing and Transferring of Personal Data
Personal Data that you provide to us is stored internally or through a data management system. Your Personal Data will only be accessed by those who help to obtain, manage or store that information, or who have a legitimate need to know such Personal Data (i.e., our hosting provider, newsletter provider, payment processors or team members).
We retain your Personal Data for the minimum amount of time necessary to provide you with the information and / or services that you requested from us. We may include certain Personal Data for longer periods of time if necessary for legal, contractual and accounting obligations.
To use certain features of the Website or its content, you may need a username and password. You are responsible for maintaining the confidentiality of the username and password, and you are responsible for all activities, whether by you or by others, that occur under your username or password and within your account. We cannot and will not be liable for any loss or damage arising from your failure to protect your username, password or account information. If you share your username or password with others, they may be able to obtain access to your Personal Data at your own risk.
You agree to notify us immediately of any unauthorized or improper use of your username or password or any other breach of security. To help protect against unauthorized or improper use, make sure that you log out at the end of each session requiring your username and password.
We will use our best efforts to keep your username and password(s) private and will not otherwise share your password(s) without your consent, except as necessary when the law requires it or in the good faith belief that such action is necessary, particularly when disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.
How You Can Access, Update or Delete Your Personal Data
You have the right to:
1. Request information about how your Personal Data is being used and request a copy of what Personal Data we use.
2. Restrict processing if you think the Personal Data is not accurate, unlawful, or no longer needed.
3. Rectify or erase Personal Data and receive confirmation of the rectification or erasure. (You have the “right to be forgotten”).
4. Withdraw your consent at any time to the processing of your Personal Data.
5. Lodge a complaint with a supervisory authority if you feel we are using your Personal Data unlawfully.
6. Receive Personal Data portability and transference to another controller without our hinderance.
7. Object to our use of your Personal Data.
8. Not be subject to an automated decision based solely on automatic processing, including profiling, which legally or significantly affects you.
You may unsubscribe from our e-newsletters or updates at any time through the unsubscribe link at the footer of all email communications. If you have questions or are experiencing problems unsubscribing, please contact us at [firstname.lastname@example.org].
We take commercially reasonable steps to protect the Personal Data you provide to us from misuse, disclosure or unauthorized access. We only share your Personal Data with trusted third parties who use the same level of care in processing your Personal Data. That being said, we cannot guarantee that your Personal Data will always be secure due to technology or security breaches. Should there be a data breach of which we are aware, we will inform you immediately.
We have a no spam policy and provide you with the ability to opt-out of our communications by selecting the unsubscribe link at the footer of all e-mails. We have taken the necessary steps to ensure that we are compliant with the CAN-SPAM Act of 2003 by never sending out misleading information. We will not sell, rent or share your email address.
Third Party Websites
We may link to other websites on our Website. We have no responsibility or liability for the content and activities of any other individual, company or entity whose website or materials may be linked to our Website or its content, and thus we cannot be held liable for the privacy of the information on their website or that you voluntarily share with their website. Please review their privacy policies for guidelines as to how they respectively store, use and protect the privacy of your Personal Data.
We follow the Children’s Online Privacy Protection Act (COPPA). Our website is not designed for use by anyone under the age of 18. We do not knowingly collect PII from a child under the age of 18. Please contact us if your child has provided personal information to us and we will delete the information. If we discover on our own that a child under 18 has been accessing our website, we will delete this information soon after we discover it.
Notification of Changes
Data Controller and Processors
We are the data controllers as we are collecting and using your Personal Data. We use trusted third parties as our data processors for technical and organizational purposes, including for payments and email marketing. We use reasonable efforts to make sure our data processors are GDPR- compliant.
Contacting the The Empowerment Agency
Updated as of 5/25/2018