This Policy was last changed on May 17, 2018
Welcome to The Freedom Promise (“The Freedom Promise”, “we” or “us”). We operate this website (the “Site”) and other health, wellness, diet and fitness websites that are part of the The Freedom Promise Network (collectively the “Sites”), including the network’s flagship property at infinitewellness.com. The Sites provide a variety of online services and products, including articles, blogs, newsletters, tools, and social networking platforms (collectively, the “Services”). We are strongly committed to protecting the privacy of your information and providing a safe and secure environment for you, our users.
To be clear about the terminology we are using, when we use the phrase “Personal Information” in this Policy, we mean information about you that is personally identifiable, like your name, address, e-mail address, or phone number, as well as other non-public information that is associated with this personal information. When we use the phrase “Anonymous Information” in this Policy, we mean information that is not associated with or linked to your Personal Information. Anonymous Information does not enable identification of or contact with individual persons.
By visiting this Site or using the Services, you are accepting the policies and practices described in this Policy. Each time you visit the Site or use the Services, you agree and expressly consent to our collection, use, and disclosure of the information that you provide as described in this Policy.
Your Personal Information may be processed by us in the country where it was collected as well as other countries (including the United States) where laws regarding processing of Personal Information may be less stringent than the laws in your country.
This Policy applies to all sites Services that are operated by us, including this Site. In addition to this general policy, each Site may have additional privacy provisions that are specific to the particular site. These supplemental disclosures are made in the site-specific addenda below or in a disclosure adjacent to the particular Service at the time we collect the information. These supplemental disclosures also govern the use of your information.
The Information We Gather
We collect information about you in three ways:
Information You Voluntarily Provide Us
We collect and maintain information that you voluntarily submit to us during your use of the Sites and Services. For example:
- when you register for a Site, you may provide us certain information including your name, email address, screen name, password, demographic information, and the health topics that interest you;
- to engage a Site’s social networking function, you may add to your profile by providing information about your interests or health topics. For example, your profile may list your favorite healthy foods or movie;
- if you are registering for a customized program, you may provide us answers to questions we use to provide you the program;
- if you sign-up to receive a newsletter, enter a contest or participate in social networking activities, we may require that you provide us contact information (e.g., email or physical address);
- if you purchase a product or service through the Site, we collect credit card information, and
- you may provide us with personal information in the course of email, customer support interactions, and surveys.
You can choose not to provide us with certain information, but this may stop you from gaining access to a Service or limit the features that you can use. For more information on the types of information we collect, please see the How We Use Your Information section below.
Information We Collect Through Your Use Of The Site
As you use the Site and Services, certain information may also be passively collected. Through technologies like cookies, pixels, beacons and log files, we may collect information about how you use the Site and the Services. For example, we may determine through your IP address that you are located in New York City and we may deliver advertisements promoting New York City-based businesses. By knowing about you, we can deliver more helpful information, programs, tools, and advertisements. Please see the sections below: To Target Advertising and Cookies, Web Beacons and Log Information for more information.
Information We Receive From Third Parties
How We Use Your Information
We will use your Personal Information in the ways described below or described at the time that the information is collected.
To Target Advertising
We believe that advertising on the Internet is more interesting to you when it is relevant. Accordingly, we customize the advertisements that you see based upon (i) the information that you knowingly provide us (e.g., age, gender, stated health interests and other information in your profile); (ii) geographic location which we determine through your IP address; (iii) data we receive from third parties or (iv) your behavior on this Site or other Sites.
To assist us with the last listed category, a practice known as “Online Behavioral Advertising”, we may engage third party vendors. With the help of a cookie that our vendors place on your browser when you visit a page of the Site, we determine your interests and target advertisements and promotions based on those interests. For example, if you read an article about a particular health condition on the Site, we may determine that you are interested in that topic and through the use of the vendor’s cookie, we may later serve you an advertisement for a product intended to help sufferers of the particular health condition. The advertisement may appear when you are visiting a different section of this Site, another Site or any other website on the Internet if the website also has a relationship with our vendor.
We understand that some people prefer not to receive targeted advertising and there are a few ways that you can limit the customization of the advertising we deliver to you.
You can limit the way that we target advertising based on your self-reported interests and some other information in your profile by clicking on the “profile” section of this Site and deleting or modifying the information. Please see the section below on Updating and Control of Your Personal Information for more information.
Please note that if you have registered on multiple Sites, you’ll need to modify your profile on each site. In addition, you can delete the cookies that we have placed on your browser. Please see the section below on Cookies, Web Beacons and Log Information for more information.
To Provide The Sites And Services
In general, we use your Personal Information as necessary or appropriate to:
- administer your account;
- register you and provide you access to the Site or Services;
- respond to your inquiries or requests that you direct to us;
- send communications and administrative emails about the Site or Services;
- personalize and better tailor the features, performance, and support of the Site and Services for your use;
- send you promotional/marketing information, newsletters, offers or other information regarding opportunities and functionality that we think would be of particular interest to you (provided that we will not give your Personal Information to any third party advertising partner without your consent);
- improve the quality of the Site and the Services, and
- analyze, benchmark and conduct research on, user data and user interactions with the Site and Services
Cookies, Web Beacons, and Log Information
- An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. We, or our service providers, may track your IP Address when you access the Sites or Services to assist with delivering geographically targeted advertisements.
How We Disclose Information to Third Parties
We know how important it is to keep the information you’ve entrusted to us confidential. We will not rent, sell or share your Personal Information with third parties except as specifically approved or under the circumstances described below. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Policy, you should not use the Site or Services.
Disclosure For Legal Reasons
We may disclose and release your Personal Information to third parties: (a) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (b) in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to our system or network, or cases in which we believe it is reasonably necessary to investigate or prevent harm, fraud, abuse, illegal conduct or a violation or alleged violation of this Policy or other agreement we may have with you.
Agents and Contractors
We may provide your Personal Information to third-party service providers who work on our behalf or help us to operate our business, the Site and the Services. Examples of such service providers include vendors and suppliers that provide us with technology, services, and/or content for sending email, analyzing data, providing marketing assistance, processing payments (including credit card payments), and providing customer service. Access to your Personal Information by these service providers is limited to the information reasonably necessary to perform its limited function. These service providers have an obligation under their contracts with us to keep your Personal Information confidential.
Aggregated, Anonymous Information
We may share aggregated Anonymous Information about you with third parties. Aggregated information is your Anonymous Information that is combined with the Anonymous Information of other users and does not allow you to be identified or contacted. Depending on the circumstances, we may or may not charge third parties for this aggregated information, or limit the third parties’ use of the aggregated information.
Contests, Sweepstakes, and Polls
Sponsors – And Other Ways That You Approve At The Time Of Collection
Within Our Company; Changes To Our Company
We may share all or some of your Personal Information with any of our subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Policy.
Message Boards And Chats
We may make message boards, chat rooms, and other interactive forums available as part of the Services. You should be aware that any information which you post to these interactive forums or otherwise choose to make publicly available, including your Personal Information, may be disclosed and available to all users who have access to that portion of the Site or Services, and is therefore no longer private. By using these interactive forums, you agree that we are not responsible for any information that you disclose or communicate in such forums, and any disclosures you make are at your own risk.
The Site and Services are not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on the Site or through the Services. If we later obtain actual knowledge that a user is under 13 years of age, we will take steps to remove that user’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at so that we may delete and remove such child’s information from our systems.
Updating and Control of Your Personal Information
We offer you choices regarding the collection, use, and sharing of your Personal Information. When you receive promotional communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional e-mail or newsletter you receive or by editing your preference to receive these communications within the “Manage My Email” or similar feature on the individual Sites when you are logged in as a registered user. Please note that despite your indicated email preferences, we may send you administrative emails regarding the Site and the Services, including, for example, administrative confirmations, and notices of updates to our Policy if we choose to provide such notices to you in this manner.
If your Personal Information changes or if you no longer desire to use or access one of the Sites or Services, we encourage you to correct, update, or remove the Personal Information from your profile. Keep in mind, however, that even if you delete information from your profile, we may retain your Personal Information in conformance with our data retention policy and there may be residual Personal Information that remains within our databases, access logs, and other records. In addition, we are not responsible for updating or removing your Personal Information contained in the lists or databases of third parties who have been provided information as permitted by this Policy.
Co-branded Sections Of The Sites
Third Party Links
The Sites may link to websites operated by third parties that we do not control. We do not monitor, control, or endorse the information collection or privacy practices of any third parties. We strongly encourage you to become familiar with the privacy practices of every website you visit and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to information collected by us through the Sites or Services and does not apply to these third party websites. The ability to access information of third parties from the Sites or Services, or links to other websites or locations, is for your convenience only and does not signify our endorsement of such third parties, their products, services, websites, locations or their content.
Ad Networks And Third Party Cookies
We place a priority on the security of Personal Information, and we undertake reasonable security measures to protect the data that resides on our servers. We also uses secure server software (SSL) to process all financial transactions that occur on the Site. SSL technology can encrypt Personal Information transmitted over the Internet. However, no security system is impenetrable. We do not warrant the security of our servers, nor do we warrant that your information, including Personal Information, will be completely secure or not be intercepted while being transmitted over the Internet.
Your Rights Under the GDPR
If you are a citizen or a resident of a country in the European Union, the GDPR grants you the following rights:
Access To Your Personal Data
You have the right to receive a copy of your personal data that is subject to processing by The Freedom Promise. Ordinary requests will be granted without charge to You within one calendar month of when you make the request. In cases of excessive, unreasonable, or repeated requests The Freedom Promise may charge you a reasonable fee and may require additional time to grant your request. Also, The Freedom Promise may use reasonable means to confirm your identity before granting any request for data so as to prevent granting fraudulent requests. To request a copy of your personal data, please contact us by e-mail at firstname.lastname@example.org
To Have Your Data Corrected
If your personal data is erroneous or outdated, you have the right to have it corrected. To do so, please contact The Freedom Promise via e-mail at email@example.com.
To Be Forgotten
You have the right to be forgotten by The Freedom Promise. You may exercise this right by e-mailing us at firstname.lastname@example.org. We will comply with your request, at no charge to you, within one calendar month by deleting your account, along with all of your personally-identifiable data that is subject to any The Freedom Promise processing. Naturally, after we grant your request you will not have access to any The Freedom Promise products or services unless and until you open a new The Freedom Promise account. The Freedom Promise may use reasonable means to confirm your identity before granting any request for data so as to prevent the granting of fraudulent requests.
To Restrict Processing Of Your Data
You can request that your data not be processed via The Freedom Promise partners. You can make that request by e-mailing us at email@example.com, if you wish, you can even specify which third parties to restrict from processing your data. We will respond to your request, at no charge to you, within thirty (30) days from when you make your request. Please be advised that some of our partners, e.g., Stripe.com, are essential to The Freedom Promise services, so that if you block processing by them, The Freedom Promise’ services may be unavailable to you.
You have the right to receive a copy of your personal data that is subject to processing by The Freedom Promise in a portable format, or to have it transferred directly from The Freedom Promise to another party. Ordinary requests will be granted without charge to you within one calendar month of when you make the request. The Freedom Promise may use reasonable means to confirm your identity before granting any request to transfer data to you or another party so as to prevent granting fraudulent requests. To request a copy of your personal data in a portable format, or to request a direct transfer of your data, please contact us by e-mail at firstname.lastname@example.org
Data Controller and Processors Under GDPR
We are the data controllers as we are collecting and using your Personal Data. We use trusted third parties as our data processors for technical and organizational purposes, including for payments and email marketing. We use reasonable efforts to make sure our data processors are GDPR-compliant.
Your Responsibility Under GDPR
The Freedom Promise is a data controller and will comply with its obligations under the GDPR; but with respect to your customers, you are probably a data controller or data subject, and if any of your customers is a citizen or a resident of a country in the European Union, then you must ensure that you comply with your obligations as a data controller or data subject under the GDPR; namely, you must ensure that you afford your Customers the GDPR rights identified above. The Freedom Promise sells business and markeing/coaching programs, it does not provide legal advice or legal services, nor does it sell a “”one-for-you” GDPR compliance package. Please consult legal counsel of your own choosing for advice on what you need to do to comply with GDPR.
How To Contact Us
If you have any questions regarding privacy or this Policy, you may contact us as follows:
Address: The Freedom Promise LLC
1385 York Avenue, Suite 24F
New York, NY 10021
We reserve the right to change, modify, add or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt-out of such differing uses. Your continued use of the Site or Services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.