PRIVACY POLICY

Last modified: July 20, 2024

PLEASE READ THIS PRIVACY POLICY CAREFULLY to understand our policies and practices regarding your information.

Thank you for visiting www.ashleyeaster.com, a website (“Website”) operated by Ashley Easter, LLC (“We”, “us”, or “our”), the Owner and Data Controller.  Owner contact email: support@ashleyeaster.com

   

We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Policy”).  This Policy describes the types of information we may collect from you or that you may provide to us when you visit our Website, as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. 

Acceptance of the terms of this Policy is a portion of the consideration required for your right to access and use our Website.  Only by accepting these terms do you have the right to use our Website.  Accessing, visiting, viewing, using, or communicating with our Website is construed as your acceptance of the terms of this Policy.  If you do not agree with the terms of this Policy, please do not engage any further with our Website. 

1. PERSONS OR PARTIES COVERED

This Privacy Policy is intended to cover all visitors to this Website, all subscribers to our lists or newsletters, all subscribers to our services and programs and affiliates, and all clients and customers.  Persons who visit or view this Website, whether intentionally or unintentionally, whether solicited or unsolicited, are parties to this Privacy Policy.       

  1. Persons Excluded From This Website Are Still Covered.  In the event that a person is excluded from our Website under the Terms of Use [ToU HYPERLINK] or our Program Terms of Service [PToS HYPERLINK] or from a denial of service by the Website, who nevertheless unlawfully visits the Website, that person remains subject to the terms of this Privacy Policy.

  2. Persons Under 18 Years of Age Are Excluded From This Website.  Our Website is not intended for children under 18 years of age or who are otherwise covered by the provisions of The Children's Online Privacy Protection Act (COPPA).  We do not knowingly collect personal information from children under 18.  If you are under 18, do not use or provide any information to this Website.  If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 18, please contact us at support@ashleyeaster.com.


2. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We will only collect and process your personal data when we have lawful bases for doing so.  These lawful bases include when you provide us with your consent and/or when we have a legitimate reason or contractual obligation to collect and process your data.  We may collect and/or receive the following types of information from you:

 

  1. Personal Information.  We collect Personal Information that you provide to us which identifies you, whether directly or indirectly, such as your name, email address, phone number, or any other identifier by which you may be contacted online or offline.  We will only request the Personal Information that is required in order to fulfill our obligations to you (e.g., in order to deliver a service you have requested), as well as to comply with any legal obligations that may accompany such an exchange. 

  2. Registration and Purchasing Information.  If you register for a service and/or make a purchase through our Website, we may track certain information about the products and services you purchase.  At checkout, you will be required to provide information necessary for processing your payment.  This information is generally processed and captured by third-party vendors, such as payment processors and merchant account providers.  To the fullest extent possible, we make an effort not to capture or retain this information ourselves (unless, for example, we are requested to process a refund, follow up on the delivery of a good or service, or work with customers or vendors on resolving any errors or other scenarios).  Third-party vendors who assist us in any of our business functions will also be doing so pursuant to their own terms and conditions and privacy policies. 

  3. Other Information Directly from You.  With your prior consent, we may collect the following:  (a) information that you provide by filling in forms on our Website, register for an account, make a purchase, request further information, or report a problem with our Website;  (b) records and copies of your correspondence if you contact us;  (c) your responses to surveys and testimonials that we might ask you to complete and for research purposes;  (d) your search queries on the Website;  (e) any content that you may post, send, receive, and/or share with us when you participate in any of our interactive features, reviews, surveys, promotions, activities, workshops, events, courses, trainings, or coaching programs.

  4. Information We Collect Through Automatic Data Collection Technologies.

    1. Activity and Log Data. Information may be collected based on your use of the Website, which generally includes information about your computer hardware and software, such as:  IP addresses, operating systems, browser types, device types, URLS, access dates and times, website pages you visit, referring website information, universally unique identifiers, advertising identifiers, carrier and country location, hardware and processor information, network type, and other related data.    

    2. Cookies and Other Similar Technologies.  “Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the Website.  When you visit our Website, we may send one or more cookies to your device.  They enable us to store information about your device which helps us, amongst other things, to provide you with an enhanced experience when you browse our Website and improve the level of services and functions provided.  We may also use third parties to send you advertisements that may be of interest to you, based on information collected about your use of our Website and other websites.  To do so, these companies may place or recognize a unique cookie or similar on your browser.

      1. You can amend or “opt out” of the collection of information created through cookies or other technology by actively managing the settings on your browser or mobile device.  If you choose to reject cookies, your access to some functionality and areas of our Website may be restricted.

      2. Our Website does not support Do Not Track settings (“DNT”) at this time.  DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your website visits collected across websites when you have not interacted with that service on a page. 

    3. Third-Party Analytics. We use third-party analytics services (such as Google Analytics) to evaluate and aggregate visitor data.  These services help us evaluate visitors’ use of the Website, including time spent on certain pages, which areas of the Website receive the most traffic, how often visitors visit pages within the Website, and also provide general geographic location about visitors, the source of referred traffic (from other websites, vs search engines, etc).  These third-party analytic services use cookies and other technologies to help analyze and provide us the data.  By providing your consent to this Privacy Policy, you consent to the collection and review of data about you by these analytics providers in the manner and for the purposes set out herein.  For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics.  If you opt out of any service, you may not enjoy the full functionality of our Website. 

    4. Other Third Party Tracking Tools.  We may also collect or receive information from third parties, such as Facebook, Instagram and/or other third party social media and similar sites.


3. HOW WE USE YOUR INFORMATION 

We use the information collected to: 

  1. Present to you our Website and its contents;

  2. Provide our services, process orders, and administer our programs;

  3. Maintain and improve our Website, services and/or program offerings;

  4. Provide you with a more customized service and experience; 

  5. Follow up with you after an email, phone or web-based inquiry, respond to your requests, and provide customer service, including in response to any problems that may arise, such as difficulties in navigating our Website or accessing certain features;

  6. Notify you about changes to our Website or any products or services we offer or provide through it;

  7. Allow you to participate in interactive features;

  8. Send you our direct marketing materials such as newsletters, text messages, and email campaigns;

  9. Solicit your feedback, and to inform you about our products and services and those of our third-party marketing partners that we feel may be of interest or value to you;

  10. Personalize or display advertisements to you on third party platforms; 

  11. Provide you with notices about your account/subscription, including expiration and renewal notices; 

  12. Fulfill our legal or contractual obligations to you and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; and

  13. Fulfill any other purpose for which you provide it.


4. HOW WE SHARE INFORMATION WITH OTHERS

  1. Third-Party Service Providers.  We engage third parties to perform services on our behalf (“Service Providers”) that help us in the collection and processing of your information.  When we transfer your information, we require all our Service Providers to maintain the privacy, confidentiality and security of the Personal Information and data.

    The categories of Service Providers with whom we work include but are not limited to:  website hosting and analytics provider(s);  website and web form plug-ins and related third party services that allow us to maintain an up-to-date online platform and communicate with you electronically;  communication and marketing support, including email and text messaging service providers or providers to assist in managing email and text correspondence with our visitors, customers, and list;  hosted shopping cart platform and payment processor(s) and/or merchant account(s) to help us transact sales online and follow up with you regarding any purchases;  video conferencing and audio/visual recording and hosting services;  online course hosting services;  and customer and membership account hosting and management services.  

    For a list of the third-party companies that support us with the collection and processing of data in order to run our business and provide access to our online offers and services, please email a Service Provider List Request to support@ashleyeaster.com.

  2. Law Enforcement and Internal Operations.  Personal Information may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against us or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and debugging purposes; or (iv) to protect the rights, property or safety of Ashley Easter, LLC, our Website, its users, or members of the general public.  We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law.  However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third party request to compel disclosure of your information.

  3. Affiliates and Business Transfer.  We may share your Personal Information with our subsidiaries and affiliates.  Ashley Easter, LLC may also sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy.  Under such circumstances, we will use commercially reasonable efforts to notify our users if their Personal Information is to be disclosed or transferred and/or becomes subject to a different privacy policy.

  4. Harmful and False.  We may share your Personal Information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ashley Easter, LLC, our Website, services, users, clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5. HOW TO ACCESS YOUR PERSONAL INFORMATION

You may access, review and make changes to your Personal Information via instructions found on the Website or by emailing us at support@ashleyeaster.com.  To manage your receipt of marketing and non-transactional communications, you may unsubscribe by clicking the “unsubscribe” link located on the bottom of any related email from us.  Emails related to the purchase or delivery of orders are provided automatically – Customers are not able to opt out of transactional emails.  We will try to accommodate any requests related to the management of Personal Information in a timely manner.  However, it may not always be possible to completely remove or modify information in our databases (for example, if we have a legal obligation to keep it for a certain time frame).

6. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the Personal Information you provide to us.  We have created mechanisms to provide you with the following control over your information:

    

  1. Tracking Technologies and Advertising.  You can set your internet browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  To learn how you can manage your cookie settings in your browser, please consult your browser’s company website.  If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.

  2. Third-Party Advertising.  If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by email at support@ashleyeaster.com.

  3. Promotional Offers.  If you do not wish to have your email address or contact information used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email at support@ashleyeaster.com stating your request to opt-out.  If we have sent you a promotional email or text message, please follow the opt-out or removal instructions in the email or text message, or send us a reply asking to be omitted from future distributions.

  4. Targeted Advertising.  If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by emailing us at support@ashleyeaster.com.

We do not control third parties’ collection or use of your information to serve interest-based advertising.  However, these third parties may provide you with ways to choose not to have your information collected or used in this way.  To opt-out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”), visit: https://thenai.org/opt-out/

7. PERSONALIZED AND BEHAVIORAL ADS

We may, in conjunction with third-party marketing partners, gather usage data collected during your visit to our Website for purposes of providing relevant advertising content to you (remarketing or retargeting) through third-party marketing partners or third-party sites such as Google, Facebook, or Instagram.  

  1. Google Analytics.  As described previously, we use Google Analytics on our website. We may utilize any of the following advertising features that utilize Google advertising cookies: Remarketing with Analytics, Demographics and Interest reporting, Segments, and DoubleClick integration.  You can opt out of having your site activity available to Google Analytics by installing a browser add-on.  For more information, please visit https://support.google.com/analytics/answer/181881?hl=en.  Please note that if you opt out of any service, you may not experience the full functionality of the Website. 

  2. Google Ad Words.  We may utilize Google Ad Words, which provides certain pieces of information collected on our website to the Adwords advertising network.  To opt out of Google Ad Words, visit:  https://support.google.com/ads/answer/2662922?hl=en

  3. Other Personalized and Behavioral Advertising Services.  We may participate in other retargeting services that are similar to those described above.  

8. CALIFORNIA AND TEXAS RESIDENTS

  1. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit:  https://oag.ca.gov/privacy/ccpa.

  2. If you are a Texas resident, Texas law may provide you with additional rights regarding our use of your personal information. To learn more about your Texas privacy rights, visit: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint/consumer-privacy-rights/texas-data-privacy-and-security-act

9. VISITORS OUTSIDE THE U.S.

Our Website and its servers are located in the United States.  United States Internet laws govern all matters relating to this Website.  Any information you provide in subscribing to or visiting our Website will be transferred to the United States.  By visiting our Website and submitting information, you authorize this transfer, processing, and use. 

  1. EU visitors and the GDPR.  If you are a resident of the European Union (EU), GDPR regulations law may provide you with additional rights regarding our use of your personal information.  To learn more about your EU privacy rights, visit: https://commission.europa.eu/law/law-topic/data-protection_en

  2. UK visitors and the UK GDPR.  If you are a resident of the UK, UK GDPR regulations may provide you with additional rights regarding our use of your personal information.  To learn more about your UK privacy rights, visit: https://ico.org.uk/for-organisations/data-protection-and-the-eu/data-protection-and-the-eu-in-detail/the-uk-gdpr/

  3. Brazilian visitors and the LGPD.  If you are a resident of Brazil, LGPD regulations may provide you with additional rights regarding our use of your personal information. To learn more about your Brazilian privacy rights, visit: https://lgpd-brazil.info/     


10. SECURITY OF YOUR INFORMATION

The security of your Personal Information is very important to us, but please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure.  While we incorporate standard industry practices internally and with our Service Providers, which we believe is sufficient for the information involved, we cannot guarantee its absolute security.  Because we work with third-party businesses and vendors in various aspects of our business including operating and securing this Website, managing our communications and databases, etc., we cannot guarantee the absolute security of our collected data, nor can we guarantee that the Information you supply will not be intercepted while being transmitted to and from us over the Internet.  Any information that you provide to us via email should be treated with extra caution, as we cannot control the level of security available through email providers. 

11. PLEASE USE CAUTION WHEN SHARING YOUR INFORMATION ONLINE 

When you voluntarily make your Personal Information available online in an environment shared by other persons – including in webinars, classes, video conferences, emails, message boards, blogs, etc., – that information can be viewed, saved, collected, heard, and/or otherwise used by others outside of our company.  We are not responsible for any unauthorized third party use of information provided in these contexts.  Please take care whenever you share any information online. 

12. EXTERNAL WEBSITES

While we have carefully chosen those Service Providers and vendors with whom we work, especially those involved in the transmission of data on behalf of our business, we do not control and are not responsible for the privacy practices or content of third-party websites, including those of affiliates, business partners, sponsors, advertisers, or other websites to which we may link to.  When visiting any third-party websites, you are responsible for reviewing the privacy policy and terms of use applicable to each site. 

13. DATA INTEGRITY AND RETENTION

Ashley Easter, LLC will use your Personal Information only for the purposes for which it was collected, unless you provide prior consent.  We will take reasonable steps to ensure that your Personal Information is relevant to its intended use, accurate, complete, and current.

We will retain and use your information for as long as your account is active, as needed to provide you services, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  

14. CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page.  If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on our Website home page and/or by email to the email address specified in your account.  The date the Privacy Policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

15. CONTACT INFORMATION

To ask questions or comment about our Privacy Policy and our privacy practices, contact us at: support@ashleyeaster.com.