PRIVACY POLICY

 

Effective as of September 21, 2023

 

This privacy policy (the “Privacy Policy”) discloses the privacy practices for website https://www.fabiennejacquet.com/ (the “Site” or “Website”), owned and operated by INNOVEVE LLC (“INNOVEVE”,” “we,” “us,” or “our”). We have created this Privacy Policy to tell you what information the Website collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. By visiting and/or using the Website, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.

 

We are subject to various laws in the United States, the Personal Information Protection and Electronic Documents Act (PIPEDA) which applies in Canada, the Federal law on Protection of Personal Data in the Possession of Private Parties (FLPPDPPP) which applies in Mexico, and the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws. IMPORTANT: BY USING THE SITE AND/OR OFFERINGS AVAILABLE ON THIS SITE, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT USE THE SITE.  

 

  1. Information We Collect or Receive. In the course of operating the Website, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.
    1. Personal Information. When you make a purchase, as part of the buying and selling process, we collect the personal information you give us such as your name, address and email address. We may send you emails about our store, new products and other updates. When you browse our website and store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
    2. Payment Information. Our ecommerce store is hosted by www.fabiennejacquet.com and PayPal and Stripe (third-party payment vendors) will process the payments.  If you make a purchase, you will be required to provide us with your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (collectively, “Payment Information”). Such Payment Information will be collected and processed by our third-party payment vendors pursuant to the terms and conditions of their privacy policies and terms of use, and we do not obtain access to any Payment Information in connection with such purchases.

  

  1. Third-Party Analytics. We and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we work use third-party analytics services (i.e., Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to browsing the Website. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit https://support.google.com/a/answer/6304816?hl=en. Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the Website.
  2. Other Information. In addition to the Personal Information and Payment Information, we may receive additional information regarding you and your use of the Website; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Website (collectively, the “Other Information”). Such Other Information may include:
    1. From You. Additional information about yourself that you voluntarily provide to us, such as your product preferences.
    2. From Your Activity. We may receive information regarding:
      1. browser type and language;
      2. referring and exit pages and URLs;
      3. date and time; and
      4. details regarding your activity on the Website such as search queries and other performance and usage data.
    3. About Your Mobile Device. We may collect or receive information regarding:
      1. type of mobile device;
      2. advertising Identifier (“IDFA” or “AdID”);
      3. operating system and version (e.g., iOS, Android or Windows);
      4. carrier; and
      5. network type (WiFi, 3G, 4G, LTE).
    4. From Cookies. We may use both session cookies, which expire once you close the Website, and persistent cookies, which stay on your device until you delete them and other technologies to help us collect data and to enhance your experience. Cookies are small text files a website or an app can use to recognize a repeat visitor. We may use cookies for various purposes, including to:
      1. type of mobile device;
      2. personalize your experience;
      3. analyze which portions of the Website are visited and used most frequently; and
      4. measure and optimize advertising and promotional effectiveness.

If you do not want us to deploy cookies, you can opt out by setting your mobile device to reject cookies. You can still use the Website if you choose to disable cookies, although your ability to use some of the features may be affected.

  1. Information Collected by or Through Third-Party Advertising Companies. We may share Other Information about your activity on the Website and the App with third parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, retargeting, analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect Other Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive Other Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.
  2. How to Opt Out of Third-Party Interest-Based Advertising. If you wish to opt out of third-party interest-based advertising, please visit http://www.networkadvertising.org and http://www.aboutads.info/choices for details on how to do so. Additionally, users of mobile Devices can follow the below instructions:

Android Users

For Android devices with OS 13 and up and Google Play Services version 35.2 and up: Open your Google Settings app > My Ad Center > Select On or Off next to “Personalized ads.”

 

iOS Users

iOS 15 or Higher: Go to your Settings > Select Privacy & Security> Apple Advertising, then turn Personalized Ads on or off.

  1. How Information is Used and Shared.
    1. You authorize us to use the Personal Information, Payment Information, Geolocational Information, and the Other Information (collectively, the “Information”) to:
      1. provide and improve our Website;
      2. provide our services;
      3. administer our promotional programs;
      4. solicit your feedback; and
      5. inform you about our products and services.
    2. In order to sell our products, provide our services and administer our promotional programs, we may share the Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
    3. We may engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law
    4. In an ongoing effort to better understand our users, the Website, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the Website, the App and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the Website and the App and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
    5. We may share some or all of your Information with any of our subsidiaries, joint ventures, or other companies under common control with us.
    6. As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
    7. To the extent permitted by law, we may also disclose the Information:
      1. when required by law, court order, or other government or law enforcement authority or regulatory agency; or
      2. whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.
  2. Accessing and Modifying Information and Communication Preferences. If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same via your user settings profile or by contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to the Website (e.g., requests for support).
  3. How We Protect Your Information. We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

We limit access to PII only to specific employees, contractors and agents who have a reasonable need access to your information. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

  1. Important Notices to Non-U.S. Residents. The Website and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Website and the App, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.  For more information, see Additional Privacy Terms section below.
  2. Children. We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Services. We urge kids to check with their parents before entering information through our Website and/or Services, and we recommend that parents discuss with their kids restrictions regarding the online release of Personal Information (as defined below) to anyone they don’t know.
    By visiting our Website and/or using our Services, or by permitting your child to use our Services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. 
  1. a) Information Collected
    We do not collect any personal information from you unless you voluntarily provide it to us. When you sign up for the course or to become a user of the website (a “User”), you will be asked to provide us with certain personal information, such as your first name, last name, and email address. In this Privacy Policy, we refer to this information as “Personal Information.” Other than the online contact information required to obtain parental consent, we do not collect any Personal Information from Users under the age of 13 unless the User’s parent or legal guardian has first provided us with consent for that User to use the Services and disclose Personal Information to us. If you are a User under the age of 13, please do not send any Personal Information to us if we have not obtained prior consent from your parent or guardian. If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a User under the age of 13 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a User under the age of 13 may have provided us Personal Information in violation of this Privacy Policy, please contact us at fabienne@innoveve.com.
  2. b) Accessing and Modifying Account Information
    We strive to help parents ensure that their kids have a safe experience participating in our courses and using our Services. Parents or legal guardians can review any Personal Information collected about their child under 13 years of age, have this information deleted, request that there be no further collection or use of their child’s Personal Information, and/or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.
  3. c) Important Notice to Users Outside of the U.S.
    The Website and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Website or the Services, you consent to this transfer.
  1. Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Website. Your continued use of the Website and/or the App after we make any such changes to this Privacy Policy, will constitute your acknowledgement and acceptance of the changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer to this Privacy Policy on a regular basis.

 

ADDITIONAL PRIVACY TERMS 

Your Rights Under the GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, known as the General Data Protection Regulation (the “GDPR”).  For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

 

Right to Access The right to be provided with a copy of your personal information (the right of access)
Right to Rectification The right to require us to correct any mistakes in your personal information
Right to be Forgotten The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object

The right to object:

  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

 

Transferring Your Personal Information Out of the EEA (for users located in the EEA). To deliver services, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • With our offices in the United States;
  • With your and our service providers located outside the EEA;
  • If you are based outside the EEA; or

 

These transfers are subject to special rules under European and UK data protection law.  We will ensure the transfer complies with data protection law and all personal information will be secure. 

 

How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.  The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. 

 

Your Rights Under PIPEDA

Some or all of the Personal Information we collect may be stored or processed in jurisdictions outside of Canada, namely the United States. As a result, this information may be subject to access requests from local, state, and federal governments, courts, or law enforcement agencies in the U.S according to laws in those jurisdictions.

 

Access and Rectification: You have a right to access your personal information and to request a correction to it if you believe it is inaccurate. If you have submitted personal information and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information provided below. We may require you verify your identity before allowing you to access your personal information.

 

Your Rights Under FLPPDPPP

In accordance with the FLPPDPPP, you, at all times, have rights to access, rectification, cancellation, and opposition (the “ARCO Rights”) your personal data.  

The owner of personal data is aware that the exercising of their rights of opposition or cancellation may render the provision of services impossible.  Therefore, We shall not be responsible for any ARCO rights request which would prevent the provision of a service contracted by the user.

For the exercising of ARCO rights, the owner must send an e-mail to the designated officer noted in the Contact Us section or, submit a written request, signed by the owner of the data, sent to Our address expressing as succinctly and as clearly as possible, the request at hand.  The rights request must be labeled with the reference REQUEST TO EXERCISE ARCO RIGHTS and the full name of the owner of the data, as well as include a simple copy of the identity document of the owner of the personal data, to ensure the identity thereof.

If the rights request is made by a person other than the owner, this person must be able to demonstrate that they are an authorized agent of the owner with sufficient proof, as well as to attach copies of the identity documents of the owner of the data and the agent.

 

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 Used for a Business Purpose

In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

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 selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. 
Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.
  • Please note that we may not delete your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

How to Contact Us. If you have questions about this Privacy Policy, please e-mail us at fabienne@innoveve.com with “Privacy Policy” in the subject line.