Privacy Policy

PRIVACY POLICY

Welcome and thank you for visiting us at Turning Life Gold, LLC (collectively using “we”, “our”, or “us”). We take your privacy very seriously and have prepared this Privacy Policy to help you understand our practices regarding the collection, use, and disclosure of any personal data and information we collect from you through using this website, using any of our services, or purchasing any of our products or programs. By visiting this site, accessing or using any of our services, or purchasing any of our products or programs, you agree to this Privacy Policy as outlined below:

1.) What Data Do We Collect?

Information you give to us:
This information is given to us by signing up for any of our products, programs, or services: including our email list, registering for one of our webinars or tele-seminars, requesting free downloadable documents and content from our website, connecting with us on Social Media such as Facebook, LinkedIn, Twitter or any others, or when registering for one of our online courses, live events, or international retreats.

• Identity Data – Identity data is data that can be used to identify you. This includes:
o First and Last Name
o Title (if used)
o Social Media User Names (if you are connected to us via any social media platforms, such as Facebook or LinkedIn)
o Photographs or Videos

• Contact Data – This is any data we may use to contact you, whether Personal or Business contact information. This includes:
o Phone numbers
o Email addresses
o Billing and Delivery addresses

• Profile Information – This is any information related to your personal preferences, background, including:
o Birthdates
o Passport information (for those participating in International Retreats only)
o Dietary Restrictions & Meal Preferences (for our international retreat meal preparations)
o Any surveys or feedback forms you provide us

• Financial Data – This is any data we can use to process payments. Most of our payments are processed through PayPal, however occasionally we collect other types of financial data if you choose to pay via other means, including:
o Credit card information – If card is used for payment.
o Bank information – (Only if a wire transfer were initiated for payment)
o PayPal – Any PayPal information available to us through normal PayPal transactions, such as email, Transaction ID’s, shipping addresses, etc.

• Sensitive Data – Occasionally, due to the nature of our work as a coaching business, clients will share with us sensitive information either via email or during video-conferencing programs, such as their current fears, insecurities, psychological state, life challenges that may be in the way of their progress, physical health concerns (especially those participating in international retreats with us), and other sensitive information. We treat this information, including all email communication, and video recordings in accordance with this privacy policy and keep all Sensitive Data secure through appropriate technical security measures. See below to learn more about how we protect this data.
Information we collect about you:

• Technical Data – This is data that we collect about the technology used to connect to our websites and other technological interactions, typically from Cookies, such as opening our email communications. Much of this data comes from analytics services and Email & Customer Relationship Management (CRM) Systems. This includes:
o IP Addresses your device used to connect to the internet
o Operating System of your device
o Browser information (ie. are you on Chrome, Safari, Firefox, or any other type of browser)
o Any other related technical information

• Tracking Data – Any information that tells us about your interactions with our website, emails, Facebook pages, or any other platforms we use. We use cookies and other tracking and analytics services, to help us understand user interactions with our online presence, including:
o Information about your website visit (date and time visited, time spent on the site & on each page, page interaction information, which pages and sites visited, page response times, any errors that happened)
o Through what channel you visited our site (ie. did you click on a FB ad, did you perform a search engine search and click on a result, found a link through a 3rd party site, such as a newsletter, article written about us or by us, or any other site that linked to our website).
o Email interactions – did you open the email, did you click on any of the links

• Marketing and Communications Data – this is information about your preferences about being marketed and communicated with, including:
o Any communication that informs us if you want to subscribe or unsubscribe from our mailings or emails. Often, this comes in the form of checking a box saying you do or do not want to receive future mailings, or if you sign up for one of our free gifts.

• Aggregate Data – This is statistical or demographic data that may be used to understand general behaviors of a group of our users in accessing specific website tools or other features, email interaction behaviors, and anything else that can give us statistical behavioral data to help us understand how our users interact with our material. This data is not connected to your personal data, so cannot reveal your identity, though any data that could link to your identity would be used in accordance with this privacy policy.

2.) Why do we Collect this Data/How will this Data be Used?

• We collect this data to use in various ways including:
o Provide services to you, the client – We offer many services to our clients, including our educational programs, coaching services, and any free content we offer. We will use this data to provide you the best experience and the best value we can create. Occasionally, this will include sending you email communications, mail to your physical address, telephone communications, and any other means to ensure and create a positive user experience

o Provide Customer support and technical assistance to you, the client – Respond to requests or inquiries that you may have, troubleshoot any technical or non-technical issues or concerns, provide coaching support, and responding to any other need you, the client, may have to facilitate improved satisfaction with our services
o Communication with you, the client – About any changes to our services, updates to our products and programs, upcoming events or programs, and any other communication within the scope of the business that provides value without compromising anonymity
o Billing services – We will use information to create and send PayPal invoices and payment plans, request wire transfers, collect credit card information, and process any other form of payment for our services
o Marketing and Sales purposes – To create and customize advertising and marketing of our product and service offerings, paid or free, to current or prospective clients. These include sending marketing emails, Social Media advertisements and posts, and phone and video calls. We collect testimonials from our clients and use those in marketing with permission from those clients.
o Monitoring the use of our services, creating market insights, identifying ways to improve our services and programs, and create new programs that meet the needs of the market
o IT Administration – Allows you to participate in Zoom and other technological and/or interactive features of our programs
o Survey creation – to collect your insights, views, and satisfaction with our services and products
o Legal Proceedings – Exercising, establishing, and defending legal rights
o Any other legitimate business purpose, while ensuring anonymity with any data management involved in those business endeavors.
o We do NOT use this data for any Automated Decision Making

3.) How do we share your data?

• We share data in the following instances:
o Any member of the Turning Life Gold team when necessary to provide appropriate and quality services.
o Hotels and other 3rd parties that provide services to us and our clients. For example, during our international retreats events we provide names and dietary preferences of our clients to the hotels, when necessary, so they can provide accurate meals and other services to our clients.
o Videos and Photographs may be shared with 3rd party service providers to help create marketing collateral and other visual materials to help market or enhance our services. We do this only if we have received express written permission by you, our client.
o To comply with any applicable laws to protect, exercise, or defend the legal rights of you, us, or others.

4.) How do we safely store and secure your data?
We use appropriate technical and organizational security measures to protect all information and data that we collect and store in our computer systems, databases, and home offices. Access to this data is limited to those employees who need access to the data to provide services to you, the client, and perform the responsibilities of their roles.

Much of our data is stored on 3rd party databases that provide industry standard measures that are designed to protect your data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. These include, but are not limited to, Dropbox, Google Drive, Google Docs, Google Spreadsheets, PayPal, MailChimp, and YouTube.

Although we implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. No security measures are 100%, and we can’t guarantee there will not be a breach, with our or any 3rd party systems. We are not responsible for any breach of security of our systems or any 3rd party systems or services we use, including those listed in the previous paragraph, and any others we may use to store, manage, analyze, or aggregate data.

Please contact us at elsie@turninglifegold.com if you have any questions about how we safely store your personal information or data.

5.) How long will we store your data?

• Turning Life Gold or any of its subsidiaries will retain your personal information and data for as long as is necessary for the purposes as described in this privacy policy. This includes:
o Comply with applicable laws and any other legal obligations
o Analysis purposes for internal use, including marketing, program improvement, and customer retention

6.) What control do you have over your data?

With regards to your personal data, you have rights under data protection laws. These include the following:
• The right to be informed
o You have the right to be informed about which data we collect, how we collect it, and how we use your personal data, which we have done our best to comprehensively outline in this Privacy Policy in a clear, concise, and intelligible manner.
• The right of access
o You have the right to obtain a copy of the personal data we have collected from you, free of charge, within 1 month of requesting it.
• The right to rectification
o You have the right to have any inaccuracies in your personal data corrected, or have it completed if it’s incomplete
• The right to erasure
o In certain circumstances, you have the right to have your personal data erased from our databases, if the data is no longer necessary for its original purpose and intention when it was collected, if we are processing the data for direct marketing purposes and you no longer want that, or for any unlawful data processing
• The right to restrict processing
o In certain circumstances, you have the right to limit how your data is used and processed by us.
• The right to data portability
o You have the right to receive any personal data you have provided to us in a structured, commonly-used, machine-readable format. And you have the right to request that we transmit this data to another data controller.
• The right to object
o In certain circumstances, you have the right to object to the processing of your personal data by us, especially for direct marketing purposes.
• Rights in relation to automated decision-making and profiling.
o Automated-decision making is a decision made by automated means without any human involvement. You have a right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you. We do not engage in any Automated-Decision Making at Turning Life Gold.

7.) Opting Out

• You have the right to opt-out of any and all marketing communications from us. Unsubscribe buttons can be found at the bottom of all of our marketing emails.

8.) Do We Use Cookies?

Yes. We use cookies to recognize your browser and capture and remember certain information.

• A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyze traffic and for advertising and marketing purposes.
• Most of the modern day interactive websites use cookies to enable us to retrieve user details for each visit. Cookies are used in some areas of our site to enable the functionality of this area and ease of use for those people visiting. Some of our affiliate partners may also use cookies.

9.) International Transfer of Data

The General Data Protection Regulation (GDPR) imposes restrictions on the transfer of personal data outside the European Union, to third parties in other countries outside of the EU and other international organizations. Any personal data we collect that may be stored on servers inside the European Union and then transferred to a server, database, or other data storage or management system that is outside of the EU will be transferred to ensure your privacy rights are protected as outlined in this privacy policy.

10.) Children

To access or use the Site, you must be 18 years old or older and have the requisite power and authority to enter into this Privacy Policy. We do not collect any information from anyone under 13 years of age. Our products, services, website, advertisements, and all communications are directed at adults above the age of 18.

11.) Updating/Accessing Your Information

Please write to elsie@turninglifegold.com to access, correct, or request any information regarding your personal data that we keep.

12.) Changes to our Privacy Policy

We reserve the right to revise our privacy policy at any time by posting changes to this page. Any changes to the privacy policy will be communicated to active subscribers by email. Changes will become active immediately upon being posted on this site.

13.) Contact Us

Have any questions about our privacy policy? We know there’s a lot here, and we’d be happy to speak to you further. Please contact us at elsie@turninglifegold.com

Last Updated: September 29, 2019