Effective Date: August 9th, 2021
We at Ashley Turner, Inc. (“Company”, “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you – our visitors, users and customers.
- WHAT INFORMATION WE COLLECT
We collect information you provide directly to us. For example, we collect information when you create an online account, sign up to receive our emails, communicate with us on the Platforms or via third-party social media sites, or order our products or services. Here are some examples of data we collect about you:
- Payment Data:If you purchase a Company product or service, we collect data regarding which product or service you’ve purchased and how much you’ve paid for those products or services. We collect certain data about your purchase as necessary to process your request. You must provide certain payment and billing data directly to our third-party payment processing partners, including your name, credit card number, security code, expiration date, billing address, shipping address, and/or zip code. For your security, the Company does not have access to or store sensitive cardholder data, such as full credit card numbers or card authentication data. Payments are processed through a third-party processor, therefore, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of that third party.
- Content:In order to receive our content (for example, online webinars, e-courses, downloads, newsletters) you must provide certain information like your name and email address so that we can communicate information about that content to you. We collect data regarding which content you chose to receive, whether you accessed it, whether you purchased a product or service as a result of viewing the content, as well as any feedback in the form of responses to surveys and/or chat features that may be enabled. Such content is hosted via third-party platforms, therefore, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of that third party.
- User Account Data: When you purchase or are granted access to our products or services, you may need to create a User Account. When you create your User Account, you must provide certain information like your name, email address, username, and password. We collect data regarding which products you have access to, how much you paid for those products or services, the first date you signed into your User Account, the number of times you’ve signed into your User Account, the date of your last activity in your User Account and which lessons you’ve completed. For your security, the Company is unable to view your User Account password.
- Shared Public Content:Our Platforms permit you to publicly interact with us and other users, share content, post comments, leave reviews, and ask or answer questions. Such shared content may be publicly viewable by others depending on where it is posted. If such information is shared on a third-party platform, such as a social media site, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of that third party.
- Educational Content: When you access our products or services, we collect certain data including which courses, assignments, labs, workspaces, and quizzes you’ve started and completed; content purchases; subscriptions; completion certificates; your exchanges with instructors, teaching assistants, and other students; and essays, answers to questions, and other items submitted to satisfy course and related content requirements.
- Giveaways, Promotions, and Surveys:We may invite you to complete a survey, provide feedback, or participate in a promotion (like a giveaway), either through our Platforms or a third-party platform. If you participate, we will collect and store the data you provide us as part of your participation, such as your name and email address and any other requested feedback. If you submit this information via a third-party platform, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
- Electronic Communications from Company:If you elect to receive email notifications from us, we collect your name and email address so that we can send you email communications about the requested information, products, and services. We collect data regarding which content you received as well as whether or when you accessed. Email communications are sent from a third-party platform, therefore, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of that third party.
- Customer Support:If you contact us (via email, phone, text, messaging platform, or through our social media channels), we may collect and store your name, email address, the content of your message, information about your business and any other data you provide.
We do not collect any information from you regarding your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, or criminal conviction and offences.
When you visit or access the Platforms, including our email communications, we use tracking technologies like cookies, pixels, web beacons, tags, and other tracking technologies to collect information about your engagement, as well as your browsing and purchasing behavior. These tracking technologies include:
- Clickstream Data: Through web site access logs, we do collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our Platforms. This information is used for internal purposes for research and development, user analysis and business decision making, all of which provides better services to our users. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties for data processing.
- Cookies: A cookie is a small amount of data that is sent to a website user’s browser from a Web server and is stored on the computer’s hard drive. We use non-identifying cookies to provide easier site navigation. Our Platforms can still be used if your browser is set to reject cookies. Our cookies do not generate personal data, do not read personal data from your machine and are never tied to anything that could be used to identify you. Information gathered through cookies may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
- Web Beacon Technologies. We may also use Web beacon or other technologies to better tailor our Platforms to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Platforms, a non-identifiable notice of that visit is generated which may be processed by Company or its data processors. Web beacons usually work in conjunction with cookies. If you do not want cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
We use these tracking technologies to deliver, measure, and improve our Platforms – whether accessed through a browser or a mobile device – in various ways. In particular, these technologies help:
- make our Platforms easier to use;
- better tailor our Platforms to your interests and needs;
- carry out profiling activities in order to learn more about you;
- offer you tailored advertising based on your behavior on our Platforms;
- provide better customer service, and compile anonymous, aggregated information that allow us to better understand our customers and visitors.
- You can opt out of Google Analytics. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
- To learn how to manage privacy and storage settings for Flash cookies, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
- Further information about deleting and blocking cookies can be found at http://www.allaboutcookies.org.
- European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/
- Internet Advertising Bureau (US): https://www.iab.com/
We will always treat your personal information with the utmost respect and never sell it to other organizations for marketing purposes.
- WHAT WE USE YOUR INFORMATION FOR
We use collected information in a variety of ways, including to:
- process and fulfill purchases of products and services and keep you informed about the status of the same;
- communicate about and administer our products, services, events, online webinars, free content, programs and promotions (such as by sending transactional emails about your purchases and/or User Account, promotional materials, newsletters and other marketing communications);
- conduct and facilitate surveys, contests, promotions, and giveaways;
- create, administer and communicate with you about your User Account;
- respond to your inquiries, comments, and applications;
- conduct promotional, marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, running targeted advertising, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand); and
- operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products and services; managing our communications and customer relationships; and performing accounting and billing activities).
The legal basis for processing your personal information as described above will typically be one of the following:
- Your consent;
- Performance of a contract with you or a relevant party;
- Our legitimate business interests; or
- Compliance with our legal obligations.
- WHO WE SHARE YOUR INFORMATION WITH
- Publicly Shared Information
Any information that you voluntarily choose to share in a public area of our Platforms (e.g., by posting a comment to a blog post, participating in a recorded course call, or leaving a review) will be available to anyone who has access to that content.
- To Company Employees, Contractors, Partners
We may share your information within the Company to our employees, contractors, and partners in order to deliver our services and products to you.
- Third-Party Providers Chosen by Us
We use third-party providers to collect and process personal information from or about you on our behalf. Examples include data analysis, marketing and advertising services, email and hosting services, customer services and support, hosting customer accounts, processing credit card payments, production, fulfillment, and collecting customer research or satisfaction surveys. They have access to the personal information needed to perform their functions.
- Third-Party Providers Chosen by You
We may share your personal information third parties approved by you. For example, social media sites you choose to link your User Account to or third party payment providers (ex., PayPal).
- Online Advertising Services
We use third-party advertising services, like Facebook and Instagram, to deliver advertising about our products and services on our Platforms, as well as other websites and applications you use. The ads may be based on information we have collected (as outlined above) and information these advertising providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.
- Analytic Services
We use third-party browser and mobile analytics services, like Google Analytics, on the Platforms. These services use tools to help us analyze your use of the Platforms, including information like the third-party website you arrive from, how often you visit, events within the Platforms, usage and performance data, and purchasing behavior. We use this data to improve the Platforms and provide information, products and services that may be of interest to you.
- Law Enforcement, Legal Process and Compliance
We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
- Change of Ownership
We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the information we share.
- KEEPING YOUR INFORMATION SECURE
We work with third-parties to ensure appropriate security measures are in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and us or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- YOUR RIGHTS
Under the General Data Protection Regulation, you may have a number of important rights free of charge. Please note that for each of the rights below we may have valid legal reasons to refuse your request. In such instances, we will let you know if that is the case. In summary, your rights include:
- Fair processing of information and transparency over how we use your use personal information;
- Access to your personal information and to certain other supplementary information that this Policy is already designed to address;
- Require us to correct any mistakes in your information which we hold;
- Require the erasure of personal information concerning you in certain situations;
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- Object at any time to processing of personal information concerning you for direct marketing;
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- Object in certain other situations to our continued processing of your personal information;
- Otherwise restrict our processing of your personal information in certain circumstances.
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’s rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- Email, call, or write to us (see “How to Contact Us” below);
- Provide us enough information to identify you (e.g., account number, user name, registration details);
- Provide us proof of your identity and address; and
- Provide us sufficient information to which your request relates (e.g., any account or reference numbers).
- Email Communications: If you would like to unsubscribe from any email marketing communications we send you, you can click on the unsubscribe link at the bottom of the message.
- Cookies and “Do Not Track” Signals: Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies, but note that doing so does not necessarily affect third party flash cookies used in connection with the Platforms. Further information about deleting and blocking cookies can be found at http://www.allaboutcookies.org.
Many web browsers support Do Not Track technology. To learn more about Do Not Track, visit: http://www.allaboutdnt.org/
Company currently does not have the ability to recognize Do Not Track Signals.
- Information from Third Parties: To manage the information we receive about you from a social media site or other third parties, you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this Policy and the information the third-party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third-party site will not apply to our use of the information we have collected directly through our Platforms.
- THIRD-PARTY SITES
The Platforms may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Platforms. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links or access are provided through the Platforms. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
- DATA TRANSFERS
In order for us to provide the products and services to you, your personal information will be stored and processed in our offices in the United States. Where data is shared with third-party data processors, your data will be captured, transferred, stored and processed in accordance with their policies, practices and in compliance with their local regulatory laws.
- DATA RETENTION
We will retain your information for as long as your account is active, as necessary to comply with our legal obligations, to resolve disputes, and enforce our agreements. If you wish to have your information deleted, please contact us (see “How to Contact Us” below).
- OUR POLICY CONCERNING MINORS
Minors should not use the Platforms. If we learn that we’ve collected personal data from a minor, we will take reasonable steps to delete it. Parents who believe that Company may have collected personal information from a minor can submit a request that it be removed by contacting us (see “How to Contact Us” below).
- NOTICE TO CALIFORNIA RESIDENTS
If you are a California resident, you have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, please contact us (see “How to Contact Us” below) with the phrase “California Shine the Light” and include your mailing address, state of residence, and email address.
- CHANGES AND UPDATES TO THIS POLICY
We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy, and in some cases, we may provide you with additional notice (such as sending you an email notification). We encourage you to review the Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
- HOW TO CONTACT US