Version 1.0 - Dated May 1, 2018
This policy is written in compliance with Data Protection Legislation and for the General Data Protection Regulation “GDPR.”
Strong Tower Coaching, LLC (the “Company” “we” “us” “our”) is committed to your privacy.
This Policy applies to any Company Services where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices.
The Company adheres to the Children's Online Privacy Protection Act (COPPA). IF YOU ARE UNDER THE AGE OF 13 YEARS OLD, YOU MUST EXIT THE SITE IMMEDIATELY. The Company will never intentionally, nor knowingly collect information on those persons under the age of 13 years old. Should the Company become aware that someone under the age of 13 has provided such information, such information will be permanently deleted immediately.
WHAT IS THE “DATA”
Data or “Personal Information” is information relating to an identified or identifiable natural person (“data subject”).
An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
Data We Collect
The data we collect consists of:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system type and version, referral source, length of visit, page views, website navigation paths and service usage);
(b) information about how you use the Website, such as the programs and features you access, items you purchase, how much time you spend on any area of the site, time of day and date you visited and how often you interact with us through the Services;
(c) information collected from communications you initiate such as questions related to our pricing, programs, products, or services via online forms or direct communication via email sent to us or via phone conversations; and feedback or information you may provide to the company through avenues such as surveys, feedback forms, direct mail sent to us, and questionnaires;
(d) information collected to facilitate your purchase of any of our products or services;
(e) information that you send to us in order to obtain an estimate, bid, or quotation;
(f) information that you provide to us for the purpose of subscribing to our website email notifications and/or newsletters;
(g) information intended for us to better understand the demographics and psychographics of our users and guests. This includes information such as age, gender, geographical location, language preferences, personality, values, opinions, attitudes, interests, and lifestyles;
(h) information such as username, password, password hints and similar security information used to create an account and authenticate users of the Services;
(i) any other information that you choose to send to us.
Additional Data We May Obtain Through Provision By Third Parties
We may also obtain certain information from third parties, including information provided through your use of third party services such as social media platforms and third party applications. The data that they collect and share is subject to their Privacy Policies and any questions or concerns should be addressed directly with the third party.
Ways we may obtain such third party data is through a third party integration where you connect your use of the Services through a third party service (e.g., a social media platform), the third party may share certain information from your third party account with us. We may also obtain such data from our affiliates, partners, or vendors, data brokers or public sources. Such data we will never share, distribute, or sell to any other parties.
(At no time and under NO circumstances shall the Company use this Data to discriminate on the basis of race, color, religion (creed), gender, gender expression, age, national origin (ancestry), disability, marital status, sexual orientation, or military status, in any of its activities, operations, or to provide its Services.)
How We Use the Data
We use the Data to:
(a) provide, improve and tailor our Services through collective, aggregated, pseudonymized, anonymized data analysis to create predictive modeling (i.e. no individual personal information is attached to these particular sets of data), to which this Policy is not intended to place any limits on our use of this type of Data;
(b) respond to and fulfill your requests;
(c) diagnose and fix issues with the Services;
(d) deliver information to you based on any notification alerts you have set, information you have requested and subscriptions you have signed up for;
(e) provide you with personalized experiences;
(f) contact you about your programs or purchases with us and our Services;
(g) provide you with customer/client support services;
(h) provide you with personalized “interest based” advertising and marketing, on behalf of ourselves as well as our sponsors, partners, and other parties;
(i) for the purposes of the security and safety of our users, guests, customers, and clients;
(j) for ensuring compliance, and for enforcement purposes. Specifically to detect, prevent, mitigate, and investigate abuses, fraudulent or illegal activities, and to enforce our agreements, including our policies and terms of service that govern your use of the services;
(k) for the purposes of resolving any disputes.
How We Might Share the Data
We may disclose your data to other members of the Company’s corporate family, or to third parties. This disclosure may be required for us to provide you access to our Services, to comply with our legal obligations, to enforce our User Agreement, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services.
We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose.
We do not sell, rent, or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your consent.
How Long We Keep the Data
We retain the Data for as long as necessary to provide the Services under the "Contract," for pursuit of our legitimate interests, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies.
Cookies, Pixels & Similar Technologies
How We Protect Your Personal Information
The Company takes data security seriously. We take a number of steps to protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.
These steps take into account the sensitivity of the data we collect and use, as well as the current state of technology. This includes, for example, storing your data on systems that have limited access and are maintained in controlled facilities. We also use, and require our vendors to use, industry standard security protocols when processing any payments for your use of the Services.
It is important to remember that no system can be guaranteed to be 100% secure. We recommend that you help us keep your data safe by taking reasonable steps such as keeping your passwords private and not disclosing sensitive personal data, such as credit card information, in places that can be accessed easily (such as via email or text messaging).
Data protection law in certain jurisdictions differentiates between the "controller" and "processor" of information. On My Wings International, LLC d/b/a is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our privacy notice, as well as any applicable national laws.
If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Those rights include:
You can withdraw your consent to receive any information from the Company at any time. You also have the right to "be forgotten" or to request that the Company permanently erase your Data, especially Data which is no longer necessary. These steps will usually be handled through an unsubscribe link in email communications you receive from us. However, should you have any difficulty unsubscribing or wish to inform us in another manner, please email us at mailto:firstname.lastname@example.org.
If there is ever a data breach, the Company will notify you within 72 hours of becoming aware of any data breach with the next steps to protect your data.
You have the right to request access to your data that the Company stores and the rights to either rectify or erase your personal data.
You have the right to seek restrictions on the processing of your data.
You have the right to object to the processing of your data and the right to the portability of your data.
To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.
We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
Unless you advise us otherwise, either through unsubscribing via a link in an email we may send you, or by contacting us directly, we will retain any information you choose to provide to us until the earlier of: (a) our decision to cease using our existing data processors, or (b) the Company decides that the value in retaining the data is outweighed by the costs of retaining it.
We may change this Policy from time to time to reflect changes in our business, the Services, or our practices and procedures. If we do make changes, we will post any changes on this page and indicate the date on which the Policy was last revised.
We encourage you to review this Policy periodically, especially before you provide personal data directly to us through the Services. Your continued use of the Services after any changes to this Policy in effect constitutes your acceptance of the revised Policy.
How to Contact Us
Strong Tower Coaching, LLC
4836 S. Joplin Street
Aurora, Colorado 80015