PRIVACY POLICY
Updated: February 14, 2024
Impact Theory, LLC (“Impact Theory,” "we," "us" or “our”) takes data privacy seriously. This privacy policy (“Privacy Policy”) describes our practices and your rights in connection with personal information that we collect, process, or share when you use the sites and services owned, hosted, or operated by Impact Theory, including ImpactTheory.com, Shop.ImpactTheory.com, and https://ImpactTheoryUniversity.com/ , (collectively, the “Services”).
This Privacy Policy applies to all users of the Services. When you access or use the Services, you agree to the terms of this Privacy Policy and our Terms of Use, and that the information contained in this Privacy Policy serves as notice at or before the point of collection for all personal information collected as described below.
Our Services may contain links to other websites, like our sponsor’s websites or links to booksellers, that may offer products or services that our customers might find useful. These third party websites may request information from you when you arrive. In such instances, the collection and use of your personal information will be governed by the privacy policy applicable to that website. We do not control the privacy policies, contents or links that appear on these websites. We encourage you to review the privacy policies of any third-party websites or services before providing any of them with your personal information.
In this Privacy Policy, we cover:
What Personal Information We Collect
How We Collect Personal Information
How We Use Personal Information
Lawful Bases for Processing
With Whom Do We Share Personal Information
Data Protection Rights
Digital Marketing
Cookie Policy
Jurisdiction-Specific Data Protection Rights
Notice of Financial Incentive
International Transfers
Security, Retention, and Storage of Personal Information
Children Under 13
How to Contact Us
What Personal Information We Collect
We (and our vendors and service providers) collect, receive, and develop several categories of personal information about you depending on the nature of your interactions with us:
We collect contact information. Contact information typically includes your name, email address, mailing address, and phone number.
We collect account information. When you sign up for an account with Impact Theory (e.g. by registering for Impact Theory University subscription programs or seminars), we collect account credentials such as username and password, and other enrollment information.
We collect location information. We may collect your precise location when you access our Services. We also collect information about your general location, using your ZIP code and IP address.
We collect online identifiers. For example, we collect IP address, unique device ID, and other information about your device.
We collect Internet and network activity information. If you use our website, we may collect information about the browser you’re using. We might also collect device identifiers. We might look at what site you came from, or what site you visit when you leave us. We may collect page interaction information (such as what areas of the websites you visit and for how long, what search terms you enter, and what products or content you view and click on), and methods used to browse away from the page. We collect this information using cookies and similar technologies described in the Cookie Policy below.
We collect information you share through the Services. We collect content you submit or make available when you use our Services, including the parts of the Services let you interact with other users or share content publicly (e.g. community forums, monthly book club events, and live Q&A trainings). We also collect information anytime you respond to surveys, provide us with feedback, participate in promotions, or use other features of the Services.
A third party collects and processes debit or credit card details (cardholder name, card number, expiration date, etc.) on our behalf to fulfill orders placed for our products and services. We do not collect or store debit or credit card information on our systems.
How We Collect Personal Information
We and our vendors collect personal information about you from various sources, directly and indirectly, including from the following:
We collect personal information directly from you. For example, we collect information if you contact us or sign up for our emails. We collect information if you make a purchase. We may also ask you to provide certain information about yourself by filling out and submitting an online form to register for a seminar or participate in a sweepstakes. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, you may be required to provide personal information, such as your name, mailing address, and email address.
We collect personal information from cookies and similar technologies. We use tracking tools like browser cookies and web beacons to collect information from and about you. We collect information when you interact with our websites, our ads, and our emails that we or our vendors send to you. We collect information about users over time and across devices when you use this website. We may have other parties collect personal information this way. Learn more about these tools, how we use them and how you can control them by reviewing our Cookie Policy below.
We get personal information about you from other sources. Other parties may give us information about you. These other parties might include business and marketing partners and social media platforms that give us information they have collected either directly or indirectly from you. Vendors that host or maintain our websites and send promotional emails for us may also give us information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with information
We combine information. For example, we may combine information that we have collected offline with information we collect online or we may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time or for additional business-related purposes.
How We Use Personal Information
We use the categories of personal information described above for the following purposes:
We use personal information to provide and administer the Services. For example, we use your personal information to create and manage user accounts and profiles, facilitate participation in our self-paced online learning platform, display customized content, and facilitate communication with other users.
We use personal information to fulfill transactions. For example, we use your personal information to process your payments, orders, and requests for courses, products, information, or features.
We use personal information to manage your account preferences and communicate with you about your account by:
responding to your questions and concerns;
sending you administrative messages and information, notifications about changes to our Services, and updates to our agreements; and
sending you information about your progress in courses, rewards programs, new services, new features, promotions, newsletters, and other available courses (which you can opt out of at any time).
We use personal information for advertising, marketing, and analytics purposes. For example, we might use your personal information to:
market and administer surveys and promotions;
learn more about you by linking your data with additional data through third-party data; providers or analyzing the data with the help of analytics service providers;
identify unique users across devices;
tailor advertisements across devices;
improve our Services and develop new products, services, and features;
analyze trends and traffic, track purchases, and track usage data; and
advertise the Services on third-party websites and applications.
We use personal information for safety, security, compliance, and due diligence purposes. We may use information to protect our company or others. We also may use information to protect our Services, as well as to detect and investigate activities that may be illegal or prohibited. We will use certain pieces of personal information to verify your identity if you make requests pursuant to this Privacy Policy. The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.
We use personal information to provide support and respond to your requests or questions. We use information to contact you in response to your feedback or other matters related to our relationship with you (such as about this Privacy Policy or our Terms of Use).
We use personal information to test, develop, analyze, and improve our products and services. We may use your personal information to make our Services better. We might use your personal information to customize your experience with us and to conduct research and analysis.
We use personal information to comply with any legal obligations and enforce our legal rights. For example, we may use personal information to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.
We may use personal information as otherwise disclosed or permitted by law, or as we may notify you from time to time.In certain circumstances, we may aggregate and/or de-identify personal information for additional purposes.
Lawful Bases for Processing
We process personal information as follows:
We process your personal information with your consent. For example, we process your personal information with your consent to provide you with communications and services you’ve signed up for (e.g. newsletters). You may revoke consent at any time. You understand that withdrawal will not affect the legality of our treatment of your personal information while your consent was in place.
We process your personal information when necessary to perform our agreements with you. This includes the terms and conditions that govern participation in any sweepstakes or promotions that we may offer.
We process your personal information in pursuit of our legitimate interests. Examples of these legitimate interests include operation and improvement of the Services, personalization of content on the Services, and protection from fraud or security threats.
We process your personal information when necessary to ensure compliance with a legal obligation to which we are subject. From time to time we may also need to process personal information to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
With Whom Do We Share Personal Information
We may your personal information with your instructors and/or students. Certain parts of the Services let you interact with other users or share content publicly, including to other students and instructors. Note that within Impact Theory University, all chat rooms, message boards, accountability groups, or other public forums available to participants are publicly visible to other participants, so you shouldn’t post any confidential or proprietary information through those features.
We will share personal information with vendors and service providers who perform services on our behalf. For example, we share information with vendors who send emails for us. We also share information with companies that help us manage and operate our websites and fulfill purchases, including our eCommerce platform and payment processor authorize.net. To understand how authorize.net collects, processes and stores your PI, please review its Terms of Service (https://www.authorize.net/about-us/terms.html) or Privacy Center (https://www.authorize.net/about-us/terms.html). We also share information with other parties like advertisers and advertising networks, social media companies, and ad tech companies that assist us in marketing and advertising our Services. We may also share information with service providers that help us investigate and prevent data incidents or audit our business and financial statements. We may share your personal information with our business partners, including for marketing purposes. For example, we might share personal information with other parties who co-sponsor a promotion or our content. Some of these partners may send you information about products or services by mail or email. They may share your information with others.
We may share your personal information with a successor to all or part of our business. For example, if part of our business is sold, we may include customer information as part of that transaction. We may share your information if there is a similar change to our corporate structure. We may also share your information with others as they conduct diligence of our corporate changes.
We will share your personal information with other parties as necessary or required by law. For example, we may share personal information to respond to a court order or subpoena. We may also share information if a government agency or investigatory body requests it. We might also share your information in order to enforce our agreements, to protect the rights of others, or to investigate potential fraud. This might include fraud we think has happened during a promotion. If you are the winner of a sweepstakes or contest, we may also share your information with anyone who reviews a winner’s list. We may share personal information for other reasons we may describe to you from time to time as permitted by law. In certain circumstances, we may share or disclose aggregated and/or de-identified personal information with third parties.
Data Protection Rights
We value your rights with respect to your personal information. In accordance with applicable law, you may be entitled to some or all of the following:
Right to Know or Request Information.
You may have the right to request confirmation of whether we store, use, or share any of your personal information and be informed about with whim your personal information has been shared.Access.
You may have the right to request copies of your personal information.Rectification.
You may have the right to change or modify your personal information that you believe is out-of-date or incorrect.Erasure or Deletion.
You may have the right to request erasure or deletion of your personal information held by Impact Theory, subject to certain exceptions as prescribed by applicable law.Restrict processing.
You may have the right to restrict our uses of your personal information under certain circumstances as prescribed by applicable law.Data portability.
You may have the right to request copies of your personal information in an electronic format and request that we send that information to you or another third party under certain circumstances as prescribed by applicable law.
Object to processing or withdraw consent.
You may have the right to object to our use of your personal information or withdraw consent where you have given it.Avoid automated decision-making.
You may have the right not to be subject to a decision based solely on automated processing, including profiling, if this has a legal or other significant effect on you as an individual, subject to certain exceptions as prescribed by applicable law.Opt-out of the sale or sharing of personal information.
You may request to opt-out of the sale or sharing of your personal information to a third party. For purposes of this Privacy Policy, “sell” means the sale, rental, release, disclosure, dissemination, availability, transfer, or other oral, written, or electronic communication of your personal information to an outside party for monetary or other valuable consideration. Please note that we do not currently sell personal information to third parties; however, we may “share” certain personal information with our partners to provide you with personalized content or targeted advertisements which may be relevant or of interest to you.Limit the Use and Disclosure of Sensitive PI.
To the extent we collect sensitive personal information, you may request that we restrict our use or disclosure of your sensitive personal information.Right to be free from discrimination.
You may have the right not to be discriminated against for exercising these rights.
If required by law, we will comply with individual’s requests, including access, correction, and/or deletion of the personal information we store in accordance with applicable law.
We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.
You can also designate an authorized agent to make a request on your behalf. If you use an authorized agent, please include written permission that you have designated that agent to make the request, or proof of the agent‘s power of attorney. We may follow up with you to verify your identity before processing your authorized agent’s request.
You may exercise the above rights by emailing us at [email protected].
Digital Marketing
We, or third-parties on our behalf, may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. To stop receiving our promotional emails, you can follow the unsubscribe link or follow the instructions in any promotional message you get from us. You may request to be removed from email, postal, phone, or other lists by emailing us at [email protected] or by writing to 9903 Santa Monica Blvd. #1107 Beverly Hills, CA 90212. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions or emails related to purchases you make on our Services.
Cookie Policy
We collect information about users over time and across different websites and devices. To do this, we and our vendors use several common tracking tools, such as browser cookies, web beacons, and similar technologies.
What are Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit www.allaboutcookies.org.
Web beacons, pixel tags and other “tracking technologies” are small strings of code placed on a web page or in an email or advertisement. These technologies allow your browser to recognize and store certain types of information such as cookies previously set, the time and date that you viewed the page with the beacon and a description of that page.
How We Use Cookies
We use first-party and third-party cookies in a range of ways to improve your experience on our website, including:
Strictly necessary cookies.
These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into secure areas of our Services. This category of cookies cannot be disabled.Functionality:
We use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer, location you are in, or volume level for video playback.Analytical cookies.
These cookies allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily. Information collected by Google Analytics cookies will be transmitted to and stored by Google on servers in the United States of America in accordance with its privacy practices. To see and overview of privacy at Google and how this applies to Google Analytics, visit https://www.google.com/intl/en/policies/privacy/.Advertising:
We use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our websites.
How You Can Manage Cookies
Most browsers are set to accept cookies by default, but you can control and manage the use of cookies on your browser or device by deleting them from your browser history. If you do not wish to receive cookies, you may set your browser to reject cookies or alert you when a cookie is dropped on your computer.
Please be advised, if you disable certain cookies, some of the features of the Services may not function properly or be available to you.
Do Not Track. We do not currently respond to browser do-not-track signals.
Jurisdiction-Specific Data Protection Rights
United States
California
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at [email protected] or write to us at the following address: 9903 Santa Monica Blvd. #1107 Beverly Hills, CA 90212. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry. Please allow up to 30 days for a response.
In the past twelve months, we have collected the following categories of PI (as described in the California Consumer Privacy Act):
Identifiers (such as name, email address);
Commercial information (such as purchase history);
Characteristics such as age, race and ethnicity (through the use of our video) ancestry, national origin, marital status, religion, sex, veteran or military status, medical condition, and mental or physical disability, and other demographic data;
Internet or electronic network activity (such as website usage information);
Geolocation data;
Audio, electronic, visual, or similar information (such a profile image); and
Inferences drawn from any of these categories.
For more information, please see the “What Personal Information We Collect” and “How We Use Personal Information” sections.
We do not sell personal information, but we may share personal information with or disclose PI to third parties as described in the “With Whom We Share PI” section, and we have shared with or disclosed personal information to such third parties within the last twelve months. We do not have actual knowledge of any sale or sharing of personal information children under the age of 16.
Nevada
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
Australia
If you are a resident of Australia, you may have the following rights:
Access.
You have right to access the personal information held about youCorrection.
You have right to correct your information when it is incorrect.Opt out of Direct Marketing.
Under the Australian Privacy Act, you have the right to opt out of the use of your personal information for the purpose of direct marketing, including in relation to personalized advertising. To learn how to opt out of personalized advertising across our Services, please review our Cookie Policy. You will still see non-personalized advertising.
You may exercise the above rights by emailing us at [email protected]. Please note that we may ask you to verify your identity before responding to such requests. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations
If you have contacted us at [email protected] with a privacy related complaint and you are not satisfied with our handling of that complaint, you may refer that complaint to the Office of the Australian Information Commissioner:
GPO Box 5218 Sydney NSW 2001
Email: [email protected]
Telephone: 1300 363 992
Website: www.oaic.gov.au
Canada
If you are a resident of Canada, you may have the following rights:
Access.
You have the right to request access to your personal information that we hold.Correction.
You are entitled to update or correct your information if it is inaccurate or incomplete.Withdraw consent.
You can withdraw your consent at any time to collection, use and disclosure of your personal information. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You may exercise the above rights by emailing us at [email protected]. Please note that we may ask you to verify your identity before responding to such requests. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations
In addition, if you have contacted us at [email protected] with a privacy related complaint and you are not satisfied with our handling of that complaint, you have the right to lodge that complaint with the Office of the Privacy Commission of Canada via the following link: https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/.
If you have any queries or concerns about how we use your personal information, please contact us at [email protected].
European Economic Area and United Kingdom
If you are located in the EEA or UK, you have the following rights:
Access.
You have the right to ask us for confirmation on whether we are processing your personal information, and access to the personal information and related information.Rectification:
You are entitled to update or correct your information if it is inaccurate or incomplete.Erasure.
You have the right to request that we erase your personal information.Restrict processing:
You have the right to request that we restrict the processing of your personal information.Object to processing:
You have the right to object to our processing of your personal information.Data portability:
You have the right to request the transfer the data that we have collected to another organization, or directly to you.
You may exercise the above rights by emailing us at [email protected]. Please note that we may ask you to verify your identity before responding to such requests. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.
In addition, if you are in the European Economic Area or the United Kingdom and you have any complaints about how we use your personal information, you have the right to lodge a complaint with the data protection authority in your country. The data protection authority for the UK is the Information Commission’s Office – whose website is https://ico.org.uk/. Contact information for data protection authorities based in the European Economic Area, Switzerland and certain non-European countries are available on the EU Commission’s website via the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
New Zealand
If you live in New Zealand and have an established business relationship with us, you have the right to:
Access.
You have the right to ask us for confirmation on whether we are processing your personal information, and request access to your personal information that we hold.Correction:
You are entitled to update or correct your information if it is inaccurate or incomplete.
You may exercise the above rights by emailing us at [email protected]. Please note that we may ask you to verify your identity before responding to such requests. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.
Notice of Financial Incentive
We offer a loyalty program on shop.impacttheory.com (ImpactaPoints) that provides certain perks and exclusive offers, including coupons. We may also provide sweepstakes, contests, or other promotions. When you sign up for ImpactaPoints or another program we may offer, we typically ask you to provide [X]. We collect the personal information you provide when you sign up for the program, which might be interpreted as a “financial incentive” program under California law or a “bona fide loyalty program” under Colorado law. The value of your personal information to us is related to the value of the free or discounted products or other benefits or prizes that are provided.
You may opt in to ImpactaPoints by joining on the shop.impacttheory.com website, available here. For contests and similar promotions, you may opt into the promotion via the means described in the applicable Officials Rules for the promotion. You may withdraw from participating in a program or promotion at any time by contacting us using the contact information listed below. We may share or disclose your personal information to third parties, as described in With Whom Do We Share Personal Information section. If you ask us to delete your personal information, your account and all related points, deals, and rewards will be deleted.
International Transfers of Information
Information about you will be transferred to, or accessed by, entities located around the world as described in this Privacy Policy. Some of these entities may be located in countries (such as the United States) that do not provide an equivalent level of protection for personal information as your home country.
We have put in place safeguards to provide adequate protection for transfers of certain information, in accordance with applicable legal requirements. For more information on the appropriate safeguards in place, or to request a copy of these safeguards, please contact us using the contact details listed in the How to Contact Us section below.
Security, Retention, and Storage of personal information
The Internet is not 100% secure. We cannot promise that your use of our Services will be completely safe. Any transmission of your data to our site is at your own risk. We encourage you to use caution when using the Internet. This includes not sharing your passwords. We keep personal information as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep information as otherwise required by law.
Children Under 13
Our Services are intended for users 13 years or older; you are not permitted to access or use the Services if you are younger than 13. We do not knowingly collect personal information from children under the age of 13 through the Services. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at [email protected], and we will endeavor to delete that information from our databases.
Changes to this Privacy Policy
We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your personal information, or to this Privacy Policy, we will provide you notice through the Services or by some other means, such as email. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.
How to Contact Us
Impact Theory
9903 Santa Monica Blvd. #1107
Beverly Hills, CA 90212