Last Updated: 2021.12.15

 

Privacy Policy

The following Privacy Policy governs the online information collection practices of Iana Lahi / Spirit Gateways®, and its associated global entities (hereafter “Company,” "we" or "us"). Specifically, it outlines the types of information that Company may gather about you while you are using https://ianalahi.com, https://spiritgateways.ianalahi.com, https://emporium.ianalahi.com, https://store.ianalahi.com, https://spiritgatewaysfouundaiton.org and other websites operated by Company (collectively, the "Website” or “Webstes"), and the ways in which we use this information. 

This Privacy Policy, including our Children's Privacy Statement, applies primarily to information which we collect online; however, the portion of this Privacy Policy that relates to the European Union’s General Data Privacy Regulation (GDPR) and the California Consumer Privacy Act (CCPA) may apply to some of the data that you provide to us offline and/or through other means, as well (for example, at a live event, via telephone, online video and/or audio conference or through the US or foreign postal mail or private mail carrier such as United Parcel Service or Federal Express).

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our Company collects information from all end users of our Internet services (the “Services”), including those who access some of our Services but do not have accounts (“Visitors”) and those who may purchase single or bundled digital Products and/or pay a monthly service fee to subscribe to the Service or Services (“Members”).

Please read this Privacy Policy carefully. By visiting and using the Website, you agree that your use of our Website, and any dispute over privacy, is governed by this Privacy Policy. In an effort to comply with changes in technology, and the adoption of new regulations and laws, we may need to change our Policy at some point in the future, in which case we'll post the changes to this Privacy Policy on this website and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Site after we post any such changes, you accept the Privacy Policy as modified.

Introduction

We may collect and store personal or other information that you voluntarily supply to us online while using the website (e.g., while on the website or in responding via email to a feature provided on the website). The website only contacts individuals who specifically request that we do so or in the event that they have signed up to receive our electronic mail messaging, attended one of our live or recorded video events, or have purchased one of our digital or physical products. The website collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and e-mail address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events or purchasing our digital or physical products. All of this information is provided to us by you.

We also collect and store information that is generated automatically as you navigate online through the website. For example, we may collect information about your computer's connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the website. If you have accessed our website via a social media platform, such as Facebook, Instagram, YouTube, Tiik Tok, LinkedIn or other such social media website we may collect information related to your social media account, such as your alias, handle, or personal identifier on that platform. We also may use a standard feature found in browser software called a "cookie" to enhance your experience with the Site, and web beacons, to access cookies, count users who visit the Site, or open HTML-formatted email messages.

We use the information we collect from you while you are using the website in a variety of ways, including using the information to customize features; advertising that may appear on the website; and, making other offers available to you via email, direct mail or otherwise. We also may provide your information to third parties, such as service providers, contractors and third-party publishers and advertisers for a variety of purposes. Unless you inform us in accordance with the process described below, we reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using the Site in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online - for example on message boards, discussion groups, communities, web logs (written blogs and video logs – vlog), through email, or in chat areas - that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

We may choose to engage with third-party advertisers, in which case some of our third-party advertisers and ad servers may place and present advertising on the Site also may collect information from you via cookies, web beacons or similar technologies. These third-party advertisers and ad servers may use the information they collect to help present their advertisements, to help measure and research the advertisements' effectiveness, or for other purposes. The use and collection of your information by these third-party advertisers and ad servers is governed by the relevant third-party's privacy policy and is not covered by our Privacy Policy. Indeed, the privacy policies of these third-party advertisers and ad servers may be different from ours. If you have any concerns about a third party's use of cookies or web beacons or use of your information, you should visit that party's website and review its privacy policy. The Site also includes links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through the Site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services. Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our websites is acquired by another company, information about our users may be among the transferred assets.

Personal Information Our Company Collects And How It Is Used

Introduction

Members may be asked to provide certain personal information when they sign up for our Products or Services including name, address, telephone number, billing information (such as a credit card number), and the type of personal computer being used to access the Services. The personal information collected from Members during the registration process (or at any other time) is used primarily to provide a customized experience while using our Products and Services. Your information will never be disclosed, traded, licensed, or sold to any third party. However, we may make limited disclosure of personal information under the specific circumstances described below.

The information you provide to us will never be disclosed, traded, licensed, or sold to a third party. However, there are specific instances, described below, where your information could be provided to a known third party.

The Types of Information We Collect and Store:

Some of the information we may collect about you and store in connection with the provision and fulfillment of our services to you may include:

How We Use Your Personal Information:

The above personal information may be used for the following purposes:

  1. To operate, improve, or promote our Service
  2. To contact you:

·       When you have opted in to receive email messaging

·       To respond to your email inquiries. Specifically, when Visitors or Members send email inquiries to us, the return email address is used to answer the email inquiry we receive. We do not use the return email address for any other purpose or share it with third parties.

  1. To monitor and analyze trends such as:

·       Purchase history

·       Sales reports

·       Behavior on the Site

·       Email clicks and opens

  1. To market our products and services through:

·       Email marketing

·       Advertising, including retargeting via Google and Facebook

·       Notifications

  1. Perform accounting, administrative, and legal tasks

Who Has Access to Your Data Within Our Organization

Within our organization, access to your data is limited to those persons who require access in order to provide you with the Products and Services you purchase from us, to contact you, and to respond to your inquiries, including requests for refund of services. Those staff members may be on teams such as: marketing, events, development, executive, customer support. Employees only have access to data that is relevant to their team, on a “need to know” basis.

Who We Share Your Data With Outside of Our Organization, and Why

Processors

We may use service providers in connection with operating and improving the website, to assist with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads if in fact ads are utilized, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations, including through the execution of CCPA and/or GDPR-compliant Data Privacy Agreements or Addenda, as applicable.

We use 3rd-party solutions for marketing and analytics. This processing occurs on third party platforms on accounts owned by Company, including, but not limited to, Google Analytics, Thinkific and/or Wix memberships, and KEAP/Infusionsoft email services. This processing is subject to our Data Privacy Agreements or Addenda with these third parties, and their respective privacy policies.

Authorities

We may access, preserve, and disclose information about you to third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Company or others.

Why We Store Information We Collect From You

We retain certain information that we collect from you while you are a member on the website, and in certain cases where you have deleted your account, for the following reasons:

When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it.

Third Party Data

Login From Integrations

For ease of use, you are also given the option to link your Iana Lahi / Spirit Gateways account on the website with your account on a third-party site such as, for example, Facebook, Instagram, LinkedIn, or Google. The third-party site will authenticate your identity, will allow you to log into Iana Lahi / Spirit Gateways platforms using the single social login buttons, and will share certain personal information that you allow us to collect. By signing-in using your third-party identity provider account (“Third Party IdP”), you are authorizing Iana Lahi / Spirit Gateways to collect, store, and use, in accordance with this Privacy Policy, any and all information that you have authorized the Third Party IdP to provide to Iana Lahi / Spirit Gateways Iana Lahi / Spirit Gateways. Such information may include your first and last name, gender, location, username, e-mail address, picture, or phone number.

You will be given the option to link your Iana Lahi / Spirit Gateways account with your social media account e.g. Facebook. When you choose to login with your social media account the social media site will: authenticate your identity, allow you to log into your Iana Lahi / Spirit Gateways account using the single social login button, and provide personal information that you agree to share with us.

Logging in this way means that you give Iana Lahi / Spirit Gateways authorization to collect, store, and use your information in accordance with this Privacy Policy. Such information may include your first and last name, gender, location, username, email address, picture, or phone number.

Third Party Integration

If you do login through a third-party account like Facebook, Instagram, or Google, we share some information with them, and they share some information with us but only for purposes of accessing your account. What is shared with us by the third-party sites depends on their Privacy Policy. We would advise that you familiarize yourself with the privacy policy of the third-party site to know what information is being shared by them.

When you login to your Iana Lahi / Spirit Gateways account with your social media or Google account we also share some basic account information with your social media and/or email provider. What we share with the social media and/or email provider depends on their Privacy Policy. We advise you to check the Privacy Policy of the social media site to familiarize yourself with the information they request from us.

Affiliate Links

Occasionally you may have clicked on one of Iana Lahi / Spirit Gateways affiliate links and signed up or bought something via that link. In this case, the person or organization in charge of the affiliate link will have the information that you have submitted. This may be your email address, name, address, or whatever else they asked you. If you have signed up for or bought something from Iana Lahi / Spirit Gateways via an affiliate link, please check the privacy policy on their site.

Online Shopping

If you order services or products directly from our Company, we will use the personal information you provide only to process that order. We do not share this information with outside parties except to the extent necessary to complete that order.

If you complete an order for some other company(ies) that may be linked to our Site, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient’s name, address, and phone number. Our company has no control over the third parties’ use of any personal information you provide when placing such an order. Please exercise care when doing so. We recommend that you familiarize yourself with the Privacy and Terms of Use policies of any other company(ies) whose web sites you may access from our site.

Cookies and Tracking Tools

We use cookies to help you make using our website easier. You can instruct Your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Site. We use cookies for the following reasons:

We may also use Web Beacons to collect non-personal data on how you use our site, such as how long did you visit our page, what web browser you’re using, what’s your operating system, and who’s your Internet service provider. In addition, we also use Google Analytics data and may use the DoubleClick cookie to serve ads based on a user’s prior visits to our website, if in fact we choose to display advertisements. This data is collected from thousands of site visits and analyzed as a whole. This helps us build a better website to match our visitors’ needs.

Disabling Cookies and Beacons: If you are uncomfortable with the collection of such information through the use of Cookies and Beacons, we recommend disabling these features through your browser preferences, though please understand this will limit the performance and functionality of our Company’s website. Your browser documentation should provide specific procedures for disabling cookie and beacon support.

You may also opt out of the DoubleClick cookie by visiting the Google advertising opt-out page: https://www.google.com/policies/privacy/ads/

Or you may opt out of Google Analytics by visiting the Google Analytics Opt-out page: https://tools.google.com/dlpage/gaoptout

Advertiser Disclosures

Google Analytics

We may use Google Analytics Advertiser Features to optimize our business. Advertiser features include:

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Site and match the right audience with the right advertising message.

You can opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.

Facebook

As advertisers on Facebook and through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.

We abide by Facebook’s Data Use Restrictions.

Data Security and Data Privacy Regulation

Our Company’s Commitment To Data Security:

We implement a variety of administrative, managerial, and technical security measures to help protect your personal information. Our Company has various internal control standards which relate specifically to the handling of personal information. These include certain controls to help safeguard the information we collect online. Our employees are trained to understand and comply with these controls, and we communicate our Privacy Policy, practices, and guidelines to our employees. However, while we strive to protect your personal information, you must also take steps to protect your information. We urge you to take every precaution to protect your personal information while you are on the Internet.

Services and websites we interact with have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information. If we do discover a security breach affecting your data, every effort will be made to provide a notification within 72 hours of our team learning of the occurrence.

General Data Privacy Regulation (GDPR)

The GDPR took effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.

If you are a resident of the European Economic Area (EEA), or are accessing this Site from within the EEA, you have certain rights with respect to your data. We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to [email protected] with ‘GDPR’ in the subject line.

Legal Basis For Processing Personal Data Under GDPR

We may process your Personal Data under the following conditions:

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EU, to:

Exercising Of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation, and opposition by contacting us. Please note that we may ask you to verify Your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact your local data protection authority in the EEA. Contact details for data protection authorities in the European Union are available here.

Data Controller and Data Protection Officer

If you reside in a country in the European Economic Area or in Switzerland, then your personal data collected by Company is controlled by the Iana Lahi / Spirit Gateways Protection Officer is located at the same address and can also be reached by email at [email protected] and put ‘GDPR’ in the Subject line.

If you reside outside of the European Economic Area and Switzerland, then the personal data collected by Company is controlled by the Iana Lahi / Spirit Gateways, PPOB 811,Sedona, Arizona, 86339, USA, which you can also contact by email at [email protected] and put ‘Privacy’ in the Subject line.

California Consumer Privacy Act (CCPA)

The CCPA took effect on January 1, 2020, and is intended to protect the data of residents of the State of California, USA.

If you are a resident of California or are accessing this website from within California, you have certain rights with respect to your data. We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to [email protected] with ‘CCPA’ in the Subject line.

Your Rights under the CCPA

Under this Privacy Policy, and by law if you are a resident of California, you have the following rights:

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can email our CCPA contact at [email protected] with ‘CCPA’ in the Subject line.

The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we may partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. You may need to opt out on every web browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our website does not respond to Do Not Track signals.

However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children’s Privacy Statement

This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen and provides important information regarding their rights under federal law with respect to such information.

Your California Privacy Rights (California's Shine the Light Law)

Under California Civil Code Section 1798 (California's Shine the Light Law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light Law, and if you are a California resident, you can contact us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Site may contain links to other websites that are not operated by us. If You click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us at: [email protected] and putting ‘Privacy’ in the Subject line or by visiting this page on our website: https://ianalahi.com/legal