(a) Collection of Information. When you visit the Website or use the Services you provide the Company with two types of information: (i) personal information, including name and contact data, account credentials, user content, payment information, device information, usage information and browsing history, location data, and demographic information; and (ii) information we store from your browser using “cookies.” The Company uses your personal information that you provide for the performance of the Services, in our or a third parties’ legitimate interests, where you give us your consent, and for compliance with a legal obligation (see below).
We collect data from you in different ways. Some of them are direct (for example when you sign up for an account, download an app or install software). Others are by visiting the Website or interacting with us even without having an account (such as through social media). Some other information may also be collected by simply visiting an affiliate or sales partner.
Our collection endpoints include when you:
- Create an account;
- Make inquiries;
- Engage with us on social media;
- Leave comments or reviews on the Services; and
- Automated services and interactions. As you interact with the Services and the Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We may also collect tracking data when you use the Website and/or the Services, or when you click on one of our adverts.
We may receive personal data about you from various types of third parties, including:
- Technical data and/or tracking data from analytics providers, advertising networks and search information providers;
- Contact, financial and transaction data from payment providers and fraud prevention services;
The Company will share your personal information with third parties only in the ways that are described herein. The Company does not sell your personal information to third parties. The Services provide the ability to share your personal information with the Company’s service providers. We may provide information and/or personal user content to service providers to help us provide the Services. Specifically, we may use third parties to facilitate our business, such as to host the Website and the Services, to send out email updates about the Services, and to process payments for products or services offered by our subscribers. In connection with these business operations, our service providers may have access to your personal information and/or content for use for a limited time in connection with these business activities. When you sign up for the Services, we will share your personal information only as necessary for the third party to provide that service. We occasionally provide demonstrations of the Services to potential subscribers. Any information provided in a demonstration is provided in a form which protects your information.
We may be required to disclose your personal information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We do not reveal information until we have a reasonable belief that an information request by law enforcement or private litigants meets applicable legal standards. Additionally, we may share account or other information when we believe it is reasonably necessary to comply with law, to protect our interests or property, or to prevent fraud or other illegal activity perpetrated through the Website or the Services. This may include sharing information with other companies, lawyers, agents or government agencies. All such sharing of information by you on the Website is done at your own risk.
We use your internet protocol address to help diagnose problems with our server, and to administer the Website. Due to the communications standards on the World Wide Web, when you visit the Website, we automatically receive the URL of the website from which you came and the website to which you are going when you leave the Website. Additionally, advertisers receive the URL of the page you were on when you click on an advertisement on the Website. The Website also receives the internet protocol address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, your mobile device (including your unique device identifier) and mobile operating system (if you are accessing the Website using a mobile device), as well as the name of your internet service provider or your mobile carrier.
We may deliver marketing communications to you across various platforms such as email, and online. Where required by law, we will ask you to explicitly opt in to receive marketing from us. If we send you a marketing communication it will include instructions on how to opt out of receiving these communications in the future.
Honoring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising.
Where we send marketing emails, we provide unsubscribe options for your use within our emails. To update your email marketing preferences, please visit the applicable email preference center, a link to which will normally be included in emails you receive from us. In addition, you can also contact us through the Website.
Even if you opt out of receiving marketing communications by email, we may still send you service communications or important transactional information related to your accounts and subscriptions (for purposes such as providing customer support).
Online behavioral advertising (“OBA”) allows us to deliver targeted advertising to users of the Services. OBA works by showing you advertisements, or sending you marketing emails, that are based on the type of content you access or read. For example, as you browse the Services, one of the cookies placed on your device will be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests. For more information about OBA, please visit: https://www.iab.com/news/self-regulatory-principles-for-online-behavioral-advertising/.
If you want to opt out of receiving OBA it does not mean that you will no longer receive advertising when you are using the Services. It just means that we will not use your personal information for OBA and that any advertising you see will not be customized to you. You can exercise your online advertising choices at http://optout.aboutads.info. You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative’s Opt Out Tool (http://www.networkadvertising.org/choices) and in the EU at http://www.youronlinechoices.com/. If you delete cookies, use a different device, or change web browsers, you may need to opt out again.
(c) Your Rights. You may have rights under European and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.
We will honor your rights under applicable data protection laws. You have the following rights under European laws, and may have similar rights under the laws of other countries.
- Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information;
- Right to rectification: The right to have inaccurate information about you corrected or removed;
- Right to erasure (“right to be forgotten”): The right to have certain personal information about you erased;
- Right to restriction of processing: The right to request that your personal information is only used for restricted purposes;
- Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you receive from us or by visiting the Website;
- Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests;
- Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format; and
- Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent.
These rights are not absolute and they do not always apply in all cases.
In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.
In order to exercise your rights please visit the Website.
(d) “Shine the Light” Law. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes or to find out more about your opt-out rights, please contact us at:
7th Mind, Inc.
5266 Hollister Avenue, Suite 320
Santa Barbara, CA 93111
(e) Billing Information. In order to use the Website and the Services and for the Company to process any transactions you authorize, you will be required to provide your billing information, including information such as your name, address, phone number, and email. The Company will provide your information to a third party payment processing service which will store your billing information on their secure payment system for as long as is necessary for you to use the Services, and following cancellation of the Services may continue to retain such information in accordance with their then applicable policies. The Company will not retain your billing information. We may retain, however, the last four (4) digits of your credit card information and card type so that we may identify the card used in the future upon cancellation of the Services may retain such information for a period up to one (1) year to facilitate any renewal initiated by you.
(f) Data Security. We take your privacy seriously. Our engineers have put in place rigorous security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
(g) Contacting You. The Company will use your personal information to contact you regarding the Services as well as send you promotional materials. You may opt out of receiving any promotional materials by following the instructions on the Website.