Last Updated: 2021.12.15
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.
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.
Personal Information Our Company Collects And How It Is Used
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:
- Email Address
- Mailing Address
- Billing Address
- PayPal Email Address
- Masked Credit Card Information (for - refunds)
- Marital Status
- Income Range
- Parent Status
- Other responses to surveys and questionnaires
- Sign-up source
- Date of account creation
- Date of account updates
- IP address
- Time stamp
- Device type
- Operating system
- Email open clicks
- User ID
- User behavior
- Login history
- Order details
- Facebook ID
- LinkedIn ID
- Google IID
- Net Promoter Score (NPS) score
- Your rating of our support
- Telephone number
- Telephone call recordings
- Testimonials, with your authorization
- Anonymized Facebook comments
- Live location
How We Use Your Personal Information:
The above personal information may be used for the following purposes:
- To operate, improve, or promote our Service
- 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.
- To monitor and analyze trends such as:
· Purchase history
· Sales reports
· Behavior on the Site
· Email clicks and opens
- To market our products and services through:
· Email marketing
· Advertising, including retargeting via Google and Facebook
- 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
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.
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:
- So you can use our website(s);
- To ensure that we do not communicate with you if you have asked us not to;
- To provide you with a refund, if entitled;
- To better understand the traffic to our Site so that we can provide all members with the best possible experience;
- To detect and prevent abuse of our Site, illegal activities, and breaches of our Terms of Service; and
- To comply with applicable legal, tax or accounting requirements.
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
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.
Third Party Integration
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.
Cookies and Tracking Tools
- To remember your country and language preferences
- To deliver information that matches your interests
- To help us understand our audience and traffic patterns
- To let you automatically log into programs and parts of our site that require membership
- To manage and present site info displayed on our website that will be specific to you
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.
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
We may use Google Analytics Advertiser Features to optimize our business. Advertiser features include:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- Double Click Platform integrations
- Google Analytics Demographics and Interest Reporting
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.
We abide by Facebook’s Data Use Restrictions.
- Any ad data collected, received, or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data, or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
- We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
- We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
- We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.
Data Security and Data Privacy Regulation
Our Company’s Commitment To Data Security:
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@example.com with ‘GDPR’ in the subject line.
Legal Basis For Processing Personal Data Under GDPR
We may process your Personal Data under the following conditions:
- Consent: You have given your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company. Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
- In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
- Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Data we hold about you.
- Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
- Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.
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 firstname.lastname@example.org 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@example.com 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 firstname.lastname@example.org with ‘CCPA’ in the Subject line.
Your Rights under the CCPA
- The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request. The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
- The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or web page.
- The right to know about your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom we share Personal Data The specific pieces of Personal Data we collected about you
- The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer's rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
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@example.com 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.
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
- From Our "Cookie Consent" notice banner
- Or from Our "CCPA Opt-out" notice banner
- Or from Our "Do Not Sell My Personal Information" notice banner
- Or from Our "Do Not Sell My Personal Information" link
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:
- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Google Android devices
- "Limit Ad Tracking" on Apple iOS devices
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.
- This website is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the website. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the website, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Site.
- Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we also do NOT knowingly distribute such information to third parties.
- We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Site.
- Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we do NOT condition the participation of a child under thirteen in the Site’s online activities on providing personally identifiable 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
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.