Privacy Policy
BY VISITING COACHSIMONA.COM, YOU ARE CONSENTING TO OUR PRIVACY POLICY.
This privacy notice discloses the privacy practices for Impactful Growth LLC. This privacy notice addresses what information is collected, who the information is shared with, and how it is secured.
Coach Simona is a brand and trademark of Impactful Growth LLC, with registered address at 1309 Coffeen Avenue, Suite 1200, Sheridan, Wyoming, 82801, United States of America. When we speak of "Coach Simona", "we", "us", and "our company" we refer to Impactful Growth LLC.
The terms “user”, “you”, and “your” refer to site visitors, customers, and any other users of the site.
Last revised on February 19th, 2024
This notice does not cover Coach Simona’s social media profiles on social media platforms such as YouTube, TikTok, Instagram, Facebook, Pinterest, X, and Threads. We publish content on these social media platforms, but we do not own or control them. These social media platforms have their own privacy policies, and they determine how your personal information is handled when you interact with Coach Simona’s content on them.
3. WHAT WE MEAN BY PERSONAL INFORMATION
For the purposes of this notice, the terms "personal information" and "personal data" will have the same definition and can therefore be used interchangeably.
When we speak of personal information, we mean the information collected from or about you (whether directly or indirectly, automatically or manually) that can be used to identify and describe you. For example, when you purchase a product from us, your name and email address can help identify you.
4. DO WE USE COOKIES?
Yes, we use cookies and other storage technologies to store and access information on your device.
5. PERSONAL INFORMATION WE MAY COLLECT
Impactful Growth LLC collects the following data:
Information we may collect indirectly about you:
- Identifiers such as your name, email address, and phone number
- Customer records information such as your billing address and your debit/credit card information for purchases
Information we may collect indirectly about you:
- Identifiers such as your network’s IP (Internet Protocol) address, your browser’s user-agent string, and any pseudonymous cookie IDs (identifiers) saved on your device by the analytics or advertising tools we may use
- Inferences drawn from personal information from your interactions with our digital properties such as the pages on our websites you’ve visited, the forms you’ve submitted, the emails you’ve opened and clicked on, and the products you’ve purchased and used
2. WHAT THIS PRIVACY POLICY DOESN’T COVER
6. HOW WE MAY COLLECT YOUR PERSONAL INFORMATION
When you visit one of our digital properties, you become a "visitor".
Depending on the data protection law that applies to the location from which you are using our digital properties (as determined by your IP address) and the rights they may give you, we may or may not ask for your consent to collect personal information about you.
When you opt in to one of our email lists, you become a "subscriber".
Depending on the data protection law that applies to the location from which you are using our digital properties (as determined by your IP address) and the rights that they may give you, we may or may not ask for your consent to send you other communications, such as for waitlists, newsletters, and promotional offers.
When you purchase one of our products, you become a "customer".
7. HOW WE MAY USE YOUR PERSONAL INFORMATION
We may use your personal information:
- To make our digital properties work so that we can deliver our content, products, and services to you.
- To respond to any questions you may have and troubleshoot any problems you may encounter when using the content, products, and services on our digital properties.
- To send you emails, text messages, and web, push, or in-app notifications for our waitlists, newsletters, and promotional offers.
- To secure our digital properties from hackers, fraudsters, scrapers, and malicious parties that may try to take our digital properties down or use our content, products, and services in ways unlawful or not permitted by the Terms of Use.
- To help us understand how you and other visitors, subscribers, or customers like you are using our digital properties, so that we can improve them.
- To advertise to you across the web.
8. WHO WE MAY SHARE YOUR PERSONAL INFORMATION WITH
We may share visitor personal information with:
We may share subscriber personal information with:
We may share customer personal information with:
- Google (privacy notice) for web analytics and/or targeted ads on Google, YouTube, Gmail, and websites participating in the Google Display Network.
- Meta (privacy notice) for targeted ads on Facebook and Instagram.
- TikTok (privacy notice) for targeted as on TikTok.
- Pinterest (privacy notice) for targeted as on Pinterest.
- Microsoft (privacy notice) for heat mapping and replaying sessions on our digital properties.
- OneTrust (privacy notice) for determining the data privacy jurisdiction and managing cookie preferences.
- ShowIt (privacy notice) for hosting some of our websites and/or content.
- Namecheap (privacy notice) for hosting some of our websites and/or content.
- ThriveCart (privacy notice) for hosting some of our digital products.
- Amazon Web Services (privacy notice) for hosting some of our websites and/or content.
We may share subscriber personal information with:
- Any or all of the third parties with whom we may share visitor personal information.
- ClickFunnels (privacy notice) for our landing pages and opt-in and/or purchase forms for our content, products, and services.
- ConvertKit (privacy notice) for our wishlists, newsletters, promotional offers, and email marketing automations.
- Zapier (privacy notice) for integrating the different tools we use and syncing personal information between them.
We may share customer personal information with:
- Any or all of the third parties with whom we may share visitor personal information.
- Any or all of the third parties with whom we may share subscriber personal information.
- Stripe (privacy notice) for processing payments and preventing fraudulent purchases.
9. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
The information provided to you on this website, and in our products and services ("information") is accurate and true to the best of our knowledge at the time of provisioning. Nevertheless, there may inevitably be errors, mistakes, and omissions.
Impactful Growth LLC is not liable for any damages due to any errors or omissions in our products or services, delay or denial of any products or services, failure of performance of any kind, interruption in the operation and your use of our products and services, website attacks (including computer virus), hacking of information, and any other system failures or misuse of information or our products and services.
10. SECURING YOUR INFORMATION
GDPR (General Data Protection Regulation) rights
If you are a resident of a member state of the European Economic Area, you are entitled to the following rights:
California resident’s privacy rights
California Civil Code Section 1798.83 permits users who are California residents to request and obtain information about categories of personal information that we disclose to 3rd parties for direct marketing purposes and the names and addresses of all 3rd parties, we shared in the immediately preceding calendar year. If you are a California resident and would like to make this request, use the information below to contact Impactful Growth LLC.
Children under 18 years of age may request the removal of content or information posted on coachsimona.com]. To request removal, use the information below to contact Impactful Growth LLC and provide a statement that you reside in California.
YOUR RIGHTS UNDER THE CCPA
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know:
Please note that we are not required to:
Personal Information Sold or Used for a Business Purpose
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information.
Please send an email to notices@impactfulgrowth.co if you do not want your information disclosed to third parties.
Additional rights and provisions for Virginia residents
This section specifically addresses our practices under the Virginia Consumer Data Protection Act ("VCDPA") for users residing in Virginia. It explains how we collect, use, and share your personal information.
As a Virginia resident, you have certain rights regarding your personal information, including: the right to access, correct, or delete your information, right to opt-out of the sale of your personal information or targeted advertising. If you have a privacy rights request, you can submit it by emailing us at notices@impactfulgrowth.co or using the Cookies Preferences, but you may need to verify your identity first.
If you make a privacy rights request, we'll keep a record of the information you provided to us for our own records.
Personal Data Collection
Processing of Personal Data
Sharing of Personal Data
Sale of Personal Data
Targeted Advertising
Definition and Exclusions: There are circumstances where we might utilize your personal data for the purpose of targeted advertising.
We define "targeted advertising" as the practice of presenting advertisements to you that are selected based on the analysis of your personal data. This data is gathered or inferred from your activities across various nonaffiliated websites, applications, or online services, helping us to predict your preferences and interests, in accordance with the definitions set forth by the Virginia Consumer Data Protection Act (VCDPA).
It's important to clarify, as per the VCDPA, that targeted advertising excludes certain types of ads. These exceptions include:
Opt-Out Rights: You can opt out of the processing of your personal data for targeted advertising.To fully exercise your right to opt out you can contact us using the contact details provided in this document or by using the cookie consent banner We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your Rights Under the VCDPA
Access and Correction: You can request access to and correction of your personal data.
Exercising Your Rights
Responding to Your Requests
11. MODIFICATION
The privacy policy can be changed at any time. The updated version will have a “Revised” date and is effective on the “Revised” date.
12. NOTICES
All notices, requests, demands, and other communications under this agreement will be submitted in writing to notices@impactfulgrowth.co.
If you are a resident of a member state of the European Economic Area, you are entitled to the following rights:
- Know what data has been collected about you and how it has been processed
- Object to the transfer of your personal data from one electronic processing system into another
- Make changes to inaccurate information
- Withdraw consent after you have given your personal data
- Ask for your personal data to be deleted
- Informed in clear and plain language if you are asked for consent for your personal data
California resident’s privacy rights
California Civil Code Section 1798.83 permits users who are California residents to request and obtain information about categories of personal information that we disclose to 3rd parties for direct marketing purposes and the names and addresses of all 3rd parties, we shared in the immediately preceding calendar year. If you are a California resident and would like to make this request, use the information below to contact Impactful Growth LLC.
Children under 18 years of age may request the removal of content or information posted on coachsimona.com]. To request removal, use the information below to contact Impactful Growth LLC and provide a statement that you reside in California.
YOUR RIGHTS UNDER THE CCPA
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom we share personal information, if any; and
- The specific pieces of personal information we have collected about you.
Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
- Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
- The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information.
Please send an email to notices@impactfulgrowth.co if you do not want your information disclosed to third parties.
Additional rights and provisions for Virginia residents
This section specifically addresses our practices under the Virginia Consumer Data Protection Act ("VCDPA") for users residing in Virginia. It explains how we collect, use, and share your personal information.
As a Virginia resident, you have certain rights regarding your personal information, including: the right to access, correct, or delete your information, right to opt-out of the sale of your personal information or targeted advertising. If you have a privacy rights request, you can submit it by emailing us at notices@impactfulgrowth.co or using the Cookies Preferences, but you may need to verify your identity first.
If you make a privacy rights request, we'll keep a record of the information you provided to us for our own records.
Personal Data Collection
- Categories Collected: We collect identifiers, commercial information, and internet information. Sensitive data is not collected.
- No Collection of Additional Data Without Notification: We commit to not collecting more categories of personal data without informing you.
Processing of Personal Data
- Purpose and Details: For the rationale behind processing your personal data, refer to “How will we use your data”.
- Consent for New Purposes: We won't process your information for purposes not originally disclosed without your consent.
- Third Parties: Your personal data is shared with third parties as detailed in “Who will your information be shared with?”. We classify these third parties according to the purpose of data processing.
Sale of Personal Data
- Definition of Sale: In the VCDPA context, 'sale' means exchanging personal data for monetary consideration to a third party.
- Exclusions: Disclosing personal data to a processor for processing on our behalf is not a sale. Other exceptions under the VCDPA also apply.
- Some of the software used under “Who will your information be shared with?” may be considered a sale of your personal information under VCDPA.
Definition and Exclusions: There are circumstances where we might utilize your personal data for the purpose of targeted advertising.
We define "targeted advertising" as the practice of presenting advertisements to you that are selected based on the analysis of your personal data. This data is gathered or inferred from your activities across various nonaffiliated websites, applications, or online services, helping us to predict your preferences and interests, in accordance with the definitions set forth by the Virginia Consumer Data Protection Act (VCDPA).
It's important to clarify, as per the VCDPA, that targeted advertising excludes certain types of ads. These exceptions include:
- Advertisements that are shown in direct response to your request for information or feedback.
- Advertisements that are based on your activities within our own websites or online applications, including those of any affiliated websites or applications.
- Advertisements that are relevant to your current search query, or your visits to a website or online application.
- The use of personal data solely for the purpose of measuring or reporting the effectiveness, reach, or frequency of advertisements.
Opt-Out Rights: You can opt out of the processing of your personal data for targeted advertising.To fully exercise your right to opt out you can contact us using the contact details provided in this document or by using the cookie consent banner We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your Rights Under the VCDPA
Access and Correction: You can request access to and correction of your personal data.
- Deletion: You can request the deletion of your personal data.
- Data Portability: You have the right to obtain your data in a portable format.
- Opt-Out of Certain Processing: You can opt out of processing for targeted advertising, sale of data, or profiling.
- Non-Discrimination: Exercising your VCDPA rights will not lead to discrimination in service or price. Within the boundaries of legal allowances, it's possible for us to provide you with varied pricing, rates, quality levels, or a different range of goods and services including the possibility of offering goods or services at no cost. Such offerings are contingent on your voluntary involvement in legitimate programs such as loyalty schemes, reward plans, premium feature subscriptions, discount opportunities, or club card memberships.
Exercising Your Rights
- Contact Details: To exercise your rights, contact us using the provided information in this document. For us to respond to your request, we need to know who you are and which right you wish to exercise.
- Verification of Identity: We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
- On Behalf of Minors: Adults can make requests on behalf of children under their authority.
Responding to Your Requests
- Timeline: We are committed to addressing your requests promptly. Generally, we aim to respond within 45 days of receiving a request. However, if we need more time to process your request, we'll promptly inform you about the reasons for the delay and the additional time required, noting that the total response time may extend to 90 days.
- Handling of Appeals: If we decide to deny your request, we'll explain the rationale behind our decision quickly, but no later than 45 days from receiving your request. You have the right to challenge our decision. You can do so by submitting an appeal to us, using the contact information provided in this document. We will review your appeal and communicate our final decision to you in writing, including a detailed explanation for our actions or inactions, within 45 days of receiving your appeal. In the event your appeal is not accepted, you have the option to file a complaint with the Attorney General.
- Fees: There are no fees for up to two requests per year; reasonable fees may apply for additional or unfounded requests.
Additional rights and provisions for Colorado residents
This section specifically addresses our practices under the Colorado Privacy Act ("CPA") for users residing in Colorado. It explains how we collect, use, and share your personal information.
As a Colorado resident, you have certain rights regarding your personal information, including: the right to access, correct, or delete your information, right to opt-out of the sale of your personal information or targeted advertising. If you have a privacy rights request, you can submit it by emailing us at notices@impactfulgrowth.co or using the Cookies Preferences, but you may need to verify your identity first.
Personal Data Collection
- Categories Collected: We collect identifiers, commercial information, and internet information. Sensitive data is not collected.
- No Collection of Additional Data Without Notification: We commit to not collecting more categories of personal data without informing you.
Processing of Personal Data
- Purpose and Details: For the rationale behind processing your personal data, refer to “How will we use your data”.
- Consent for New Purposes: We won't process your information for purposes not originally disclosed without your consent.
Sharing of Personal Data
- Third Parties: Your personal data is shared with third parties as detailed in “Who will your information be shared with?”. We classify these third parties according to the purpose of data processing.
Sale of Personal Data
- Definition of Sale: In the CPA context, 'sale' means exchanging personal data for monetary consideration to a third party.
- Exclusions: Disclosing personal data to a processor for processing on our behalf is not a sale. Other exceptions under the CPA also apply.
- Some of the software used under “Who will your information be shared with?” may be considered a sale of your personal information under CPA.
Targeted Advertising
Definition and Exclusions: There are circumstances where we might utilize your personal data for the purpose of targeted advertising.
We define "targeted advertising" as the practice of presenting advertisements to you that are selected based on the analysis of your personal data. This data is gathered or inferred from your activities across various nonaffiliated websites, applications, or online services, helping us to predict your preferences and interests, in accordance with the definitions set forth by the Colorado Privacy Act (CPA).
It's important to clarify, as per the CPA, that targeted advertising excludes certain types of ads. These exceptions include:
- Advertisements that are shown in direct response to your request for information or feedback.
- Advertisements that are based on your activities within our own websites or online applications, including those of any affiliated websites or applications.
- Advertisements that are relevant to your current search query, or your visits to a website or online application.
- The use of personal data solely for the purpose of measuring or reporting the effectiveness, reach, or frequency of advertisements.
Opt-Out Rights: You can opt out of the processing of your personal data for targeted advertising. To fully exercise your right to opt out you can contact us using the contact details provided in this document or by using the cookie consent banner. We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your Rights Under the CPA
- Access and Correction: You can request access to and correction of your personal data.
- Deletion: You can request the deletion of your personal data.
- Data Portability: You have the right to obtain your data in a portable format.
- Opt-Out of Certain Processing: You can opt out of processing for targeted advertising, sale of data, or profiling.
Exercising your CPA rights will not lead to discrimination in service or price. Within the boundaries of legal allowances, it's possible for us to provide you with varied pricing, rates, quality levels, or a different range of goods and services including the possibility of offering goods or services at no cost. Such offerings are contingent on your voluntary involvement in legitimate programs such as loyalty schemes, reward plans, premium feature subscriptions, discount opportunities, or club card memberships.
Exercising Your Rights
- Contact Details: To exercise your rights, contact us using the provided information in this document. For us to respond to your request, we need to know who you are and which right you wish to exercise.
- Verification of Identity: We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
- On Behalf of Minors: Adults can make requests on behalf of children under their authority.
Responding to Requests
- Timeline: We are committed to addressing your requests promptly. Generally, we aim to respond within 45 days of receiving a request. However, if we need more time to process your request, we'll promptly inform you about the reasons for the delay and the additional time required, noting that the total response time may extend to 90 days.
- Handling of Appeals: If we decide to deny your request, we'll explain the rationale behind our decision quickly, but no later than 45 days from receiving your request. You have the right to challenge our decision. You can do so by submitting an appeal to us, using the contact information provided in this document. We will review your appeal and communicate our final decision to you in writing, including a detailed explanation for our actions or inactions, within 45 days of receiving your appeal. In the event your appeal is not accepted, you have the option to file a complaint with the Attorney General.
- Fees: There are no fees for up to two requests per year; reasonable fees may apply for additional or unfounded requests.
Universal Opt-Out Mechanism
Global Privacy Control (GPC): You can easily opt out of the sale of your personal data or targeted advertising through Global Privacy Control (GPC), a user-friendly privacy feature. GPC works as a setting or add-on in your browser or mobile device, letting websites know you prefer privacy. If you'd like to use GPC, you can activate it in participating browsers or through browser extensions. Click here for more information.
Additional rights and provisions for Utah residents
This section specifically addresses our practices under the Utah Consumer Privacy Act ("UCPA") for users residing in Virginia. It explains how we collect, use, and share your personal information.
As a Utah resident, you have certain rights regarding your personal information, including: the right to access, correct, or delete your information, right to opt-out of the sale of your personal information or targeted advertising. If you have a privacy rights request, you can submit it by emailing us at notices@impactfulgrowth.co or using the Cookies Preferences, but you may need to verify your identity first.
If you make a privacy rights request, we'll keep a record of the information you provided to us for our own records.
Personal Data Collection
- Categories Collected: We collect identifiers, commercial information, and internet information. Sensitive data is not collected.
- No Collection of Additional Data Without Notification: We commit to not collecting more categories of personal data without informing you.
Processing of Personal Data
- Purpose and Details: For the rationale behind processing your personal data, refer to “How will we use your data”.
- Consent for New Purposes: We won't process your information for purposes not originally disclosed without your consent.
Sharing of Personal Data
Third Parties: Your personal data is shared with third parties as detailed in “Who will your information be shared with?”. We classify these third parties according to the purpose of data processing.
Sale of Personal Data
- Definition of Sale: In the UCPA context, 'sale' means exchanging personal data for monetary consideration to a third party.
- Exclusions: Under the UCPA, sharing your personal data with a processor who manages the data for us isn't considered a sale. Also, there are other exceptions in the UCPA, like when we need to give your data to someone else so they can provide a product or service you asked for.
- Some of the software used under “Who will your information be shared with?” may be considered a sale of your personal information under UCPA.
Targeted Advertising
Definition and Exclusions: There are circumstances where we might utilize your personal data for the purpose of targeted advertising.
We define "targeted advertising" as the practice of presenting advertisements to you that are selected based on the analysis of your personal data. This data is gathered or inferred from your activities across various nonaffiliated websites, applications, or online services, helping us to predict your preferences and interests, in accordance with the definitions set forth by the Utah Consumer Privacy Act (UCPA).
It's important to clarify, as per the UCPA, that targeted advertising excludes certain types of ads. These exceptions include:
- Advertisements that are shown in direct response to your request for information or feedback.
- Advertisements that are based on your activities within our own websites or online applications, including those of any affiliated websites or applications.
- Advertisements that are relevant to your current search query, or your visits to a website or online application.
- The use of personal data solely for the purpose of measuring or reporting the effectiveness, reach, or frequency of advertisements.
Opt-Out Rights: You can opt out of the processing of your personal data for targeted advertising. To fully exercise your right to opt out you can contact us using the contact details provided in this document or by using the cookie consent banner. We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your Rights Under the UCPA
- Access and Correction: You can request access to and correction of your personal data.
- Deletion: You can request the deletion of your personal data.
- Data Portability: You have the right to obtain your data in a portable format.
- Opt-Out of Certain Processing: You can opt out of processing for targeted advertising, sale of data, or profiling.
- Non-Discrimination: Exercising your UCPA rights will not lead to discrimination in service or price. Within the boundaries of legal allowances, it's possible for us to provide you with varied pricing, rates, quality levels, or a different range of goods and services including the possibility of offering goods or services at no cost. Such offerings are contingent on your voluntary involvement in legitimate programs such as loyalty schemes, reward plans, premium feature subscriptions, discount opportunities, or club card memberships.
Exercising Your Rights
- Contact Details: To exercise your rights, contact us using the provided information in this document. For us to respond to your request, we need to know who you are and which right you wish to exercise.
- Verification of Identity: We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
- On Behalf of Minors: Adults can make requests on behalf of children under their authority.
Responding to Your Requests
- Timeline: We are committed to addressing your requests promptly. Generally, we aim to respond within 45 days of receiving a request. However, if we need more time to process your request, we'll promptly inform you about the reasons for the delay and the additional time required, noting that the total response time may extend to 90 days.
- Handling of Appeals: If we decide to deny your request, we'll explain the rationale behind our decision quickly, but no later than 45 days from receiving your request. You have the right to challenge our decision. You can do so by submitting an appeal to us, using the contact information provided in this document. We will review your appeal and communicate our final decision to you in writing, including a detailed explanation for our actions or inactions, within 45 days of receiving your appeal. In the event your appeal is not accepted, you have the option to file a complaint with the Attorney General.
- Fees: There are no fees for up to one request per year.
Additional rights and provisions for Connecticut residents
This section specifically addresses our practices under the Connecticut Data Privacy Act ("CTDPA") for users residing in Connecticut. It explains how we collect, use, and share your personal information.
As a Connecticut resident, you have certain rights regarding your personal information, including: the right to access, correct, or delete your information, right to opt-out of the sale of your personal information or targeted advertising. If you have a privacy rights request, you can submit it by emailing us at notices@impactfulgrowth.co or using the Cookies Preferences, but you may need to verify your identity first.
Personal Data Collection
- Categories Collected: We collect identifiers, commercial information, and internet information. Sensitive data is not collected.
- No Collection of Additional Data Without Notification: We commit to not collecting more categories of personal data without informing you.
Processing of Personal Data
- Purpose and Details: For the rationale behind processing your personal data, refer to “How will we use your data”.
- Consent for New Purposes: We won't process your information for purposes not originally disclosed without your consent.
- Sharing of Personal Data
- Third Parties: Your personal data is shared with third parties as detailed in “Who will your information be shared with?”. We classify these third parties according to the purpose of data processing.
Sale of Personal Data
- Definition of Sale: In the CTDPA context, 'sale' means exchanging personal data for monetary consideration to a third party.
- Exclusions: Under the CTDPA, giving your personal data to a processor who handles it for us isn't considered a sale. Also, there are some exceptions, like when we need to share your data with someone else so they can give you a product or service you've asked for.
- Some of the software used under “Who will your information be shared with?” may be considered a sale of your personal information under CTDPA.
Targeted Advertising
Definition and Exclusions: There are circumstances where we might utilize your personal data for the purpose of targeted advertising.
We define "targeted advertising" as the practice of presenting advertisements to you that are selected based on the analysis of your personal data. This data is gathered or inferred from your activities across various nonaffiliated websites, applications, or online services, helping us to predict your preferences and interests, in accordance with the definitions set forth by the Connecticut Data Privacy Act (CTDPA).
It's important to clarify, as per the CTDPA, that targeted advertising excludes certain types of ads. These exceptions include:
- Advertisements that are shown in direct response to your request for information or feedback.
- Advertisements that are based on your activities within our own websites or online applications, including those of any affiliated websites or applications.
- Advertisements that are relevant to your current search query, or your visits to a website or online application.
- The use of personal data solely for the purpose of measuring or reporting the effectiveness, reach, or frequency of advertisements.
Opt-Out Rights: You can opt out of the processing of your personal data for targeted advertising.To fully exercise your right to opt out you can contact us using the contact details provided in this document or by using the cookie consent banner.We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your Rights Under the CTDPA
- Access and Correction: You can request access to and correction of your personal data.
- Deletion: You can request the deletion of your personal data.
- Data Portability: You have the right to obtain your data in a portable format.
- Opt-Out of Certain Processing: You can opt out of processing for targeted advertising, sale of data, or profiling.
- Exercising your CTDPA rights will not lead to discrimination in service or price. Within the boundaries of legal allowances, it's possible for us to provide you with varied pricing, rates, quality levels, or a different range of goods and services including the possibility of offering goods or services at no cost. Such offerings are contingent on your voluntary involvement in legitimate programs such as loyalty schemes, reward plans, premium feature subscriptions, discount opportunities, or club card memberships.
Exercising Your Rights
- Contact Details: To exercise your rights, contact us using the provided information in this document. For us to respond to your request, we need to know who you are and which right you wish to exercise.
- Verification of Identity: We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
- On Behalf of Minors: Adults can make requests on behalf of children under their authority.
Responding to Your Requests
- Timeline: We are committed to addressing your requests promptly. Generally, we aim to respond within 45 days of receiving a request. However, if we need more time to process your request, we'll promptly inform you about the reasons for the delay and the additional time required, noting that the total response time may extend to 90 days.
- Handling of Appeals: If we decide to deny your request, we'll explain the rationale behind our decision quickly, but no later than 45 days from receiving your request. You have the right to challenge our decision. You can do so by submitting an appeal to us, using the contact information provided in this document. We will review your appeal and communicate our final decision to you in writing, including a detailed explanation for our actions or inactions, within 45 days of receiving your appeal. In the event your appeal is not accepted, you have the option to file a complaint with the Attorney General.
- Fees: There are no fees for up to one request per year.
Universal Opt-Out Mechanism
Global Privacy Control (GPC): You can easily opt out of the sale of your personal data or targeted advertising through Global Privacy Control (GPC), a user-friendly privacy feature. GPC works as a setting or add-on in your browser or mobile device, letting websites know you prefer privacy. If you'd like to use GPC, you can activate it in participating browsers or through browser extensions. Click here for more information.
11. MODIFICATION
The privacy policy can be changed at any time. The updated version will have a “Revised” date and is effective on the “Revised” date.
12. NOTICES
All notices, requests, demands, and other communications under this agreement will be submitted in writing to notices@impactfulgrowth.co.
1. WHAT THIS PRIVACY POLICY COVERS
This Privacy Notice ("notice", “privacy policy”) describes what personal information we may collect from or about you when you use our products and services, how we may use and share that personal information, and what rights you have over the personal information you may have given us or we may have collected about you.
This notice covers coachsimona.com and its related websites that we own and control, which we collectively and individually refer to as "our digital properties".
