This site is owned and operated by NATURAL SUCCESS LTD (NS) and William Whitecloud International LLC. Your privacy on the Internet is of the utmost importance to us. At NS, we want to make your experience online satisfying and safe.
Last updated May 31, 2022
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SUMMARY OF KEY POINTS
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Natural Success and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights and how can you exercise your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
1. THE INFORMATION WE COLLECT
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register for our Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include but is not limited to the following:
- phone numbers
- email addresses
- mailing addresses
- contact or authentication data
- contact preferences
- billing addresses
- debit/credit card numbers
- gender\other responses to surveys and questionnaires
- sign-up source
- date of account creation
- date of account updates
- ip address
- operating system
- device type
- user id
- email open clicks
- user behavior
- login history
- order details
- nps score
- your rating of our support
- telephone number
- testimonials, with your authorization
- anonymized Facebook comments and Amazon reviews
- live location
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe and Kartra systems. You may find their Privacy Policies (links) here: https://stripe.com/privacy and https://home.kartra.com/privacypolicy.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “PROCESSING YOUR SOCIAL LOGINS“ below.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, including but not limited to public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes but is not limited to mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.
If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.
2. PROCESSING YOUR PERSONAL INFORMATION
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, refunds, and exchanges made through the Services.
- To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “YOUR PRIVACY RIGHTS“ below.
- To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including but not limited to fraud monitoring and prevention.
- To identify, monitor, and analyze usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them, such as purchase history, sales reports, behavior on the Site, and email clicks and opens.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
- To market our products and services through: Email marketing, notifications, advertising, targeted advertising including retargeting via Google, Facebook, and other ad platforms.
We use Google Analytics Advertiser Features to optimize our business. This Advertiser features includes:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- Double Click Platform integrations
- Google Analytics Demographics and Interest Reporting
By using these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, or other third-party identifiers together to gather data about your activities on our Site. The “Remarketing” feature allows us to reach people who previously visited our Site, and match the right audience with the right advertising message.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information and to learn more on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc.
You may learn more about interest-based advertising on Facebook by visiting this page: https://www.facebook.com/help/164968693837950
If you would like to opt-out of Facebook’s interest-based ads, please follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising and participates in the opt-out programs established by the Digital Advertising Alliance, the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. You can opt-out from all participating companies through these sites.
You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
3. YOUR PERSONAL INFORMATION AND GDPR
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services
- Develop and display personalized and relevant advertising content for our users
- Analyze how our services are used so we can improve them to engage and retain users
- Support our marketing activities
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
Your Rights under the GDPR
Natural Success undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
As per the General Data Protection Regulation (GDPR), “personal data” is any information from which a person (a data subject) can be identified or potentially identified.
- Be Informed. Before your data is collected, you have the right to know how it will be collected, processed, and stored, and for what purposes.
- Request access to Your Personal Data. You have the right to know how your personal data has been collected, processed and stored. What data exists and for what purposes. You have the right to access, delete or update the information We have on You. This also enables You to request and receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to have incorrect or incomplete data corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to stop your personal data from being included in direct marketing databases.
- Request erasure of Your Personal Data. You have the right to have your personal data permanently deleted from our systems.
- Request the transfer of Your Personal Data. You have the right to move, copy, or transfer personal data from us to you or to a third-party You have chosen in a safe and secure way, in a commonly used and machine-readable format. Wherever technically possible, this also includes the right to have the data transferred directly without you having to handle the data. Please note that this right only applies to automated information which You initially provided consent for us to use or where We used the information to perform a contract with You.
- Right to Restriction of Processing. You have the right to block or suppress personal data being processed or used.If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
- Right to Not Be Subject to Automated Decision Making. You have the right to demand human intervention, rather than having important decisions made solely by algorithm.
Exercising Your GDPR Data Protection Rights
You may exercise your rights under the GDPR (rights of access, rectification, erasure, portability, restriction of processing, object to processing, to be informed and to not be subject to automated decision making).
You can make your request electronically to firstname.lastname@example.org or email@example.com
Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
If you think your data has been misused or not kept secure, you should contact us and tell us. If you’re unhappy with our response, You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
4. THE SHARING OF YOUR PERSONAL INFORMATION
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:
- Ad Networks
- Affiliate Marketing Programs
- Communication & Collaboration Tools
- Data Analytics Services
- Data Storage Service Providers
- Finance & Accounting Tools
- Payment Processors
- Performance Monitoring Tools
- Order Fulfillment Service Providers
- Product Engineering & Design Tools
- Retargeting Platforms
- Sales & Marketing Tools
- Social Networks
- Testing Tools
- User Account Registration & Authentication Services
- Website Hosting Service Providers
- Cloud Computing Services
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
- Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
5. COOKIES AND OTHER TRACKING TECHNOLOGIES
6. PROCESSING YOUR SOCIAL LOGINS
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Some of our Services may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
7. INTERNATIONAL TRANSFER OF DATA
In Short: We may transfer, store, and process your information in countries other than your own.
If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?“ above), in the United States, Australia, United Kingdom, and other countries.
We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
8. RETENTION OF DATA
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
No purpose in this notice will require us to keep your personal information for longer than twelve (12) months past the start of the idle period of the user’s account.
9. KEEPING YOUR INFORMATION SAFE
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
10. CHILDREN’S PRIVACY
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at firstname.lastname@example.org.
11. YOUR PRIVACY RIGHTS
In Short: Depending on where you are located, you are entitled to specific privacy rights. In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “CONTACTING US“ below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting Us by using the contact details provided in the section “CONTACTING US“ below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by reaching out to our support desk, or by contacting us using the details provided in the section “CONTACTING US“ below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact us using the contact information provided.
- Contact our support desk
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or Services.
If you have questions or comments about your privacy rights or to opt-out of interest-based advertising by advertisers on our Services you may email us at email@example.com.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
13. LINKS TO OTHER WEBSITES
In Short: We may have links to other websites on our Site.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
In Short: We will update this Policy as necessary to stay compliant with relevant laws.
15. CONTACTING US
If you have questions or comments about this Policy, you may email us at firstname.lastname@example.org or by contacting our support desk at https://www.naturalsuccess.io/supportdesk.