Your privacy and security is of the utmost importance to us. We describe in this policy how we collect and use information about you in your use of our services, including our platform and the website.
Who we are
We are The Attitude Advantage Program and our mission is to inspire hope and build confidence in teenagers and help restore family values through live events, coaching programs and online content. We work in conjunction with the non-profit organization called The Attitude Is Everything Foundation, Inc. (EIN: 82-1878785) The processing explained in this policy may be carried out by The Attitude Advantage Program or other data controllers such as the Attitude is Everything Foundation, Inc.
When collecting information about our customers or visitors of our website, we are, under European Union (“EU”) data protection laws, qualified as “data controller”. This means that we are responsible for deciding how we hold and use personal data about you.
How we collect your data
We collect information on leads who fill in a ‘sign up’ or contact form on our website or send us an email. We may also receive your personal data from third parties, such as Facebook and Instagram when leads express your interest for our services to them.
We collect information by automated means. When you visit our website, view one of our advertisements on a third party-owned website, or read our marketing newsletters, we automatically collect information about you via cookies, web beacons and other similar technologies. These are small files associated with information that your browser or our servers will save and return as part of your use of the website and the services for purposes such as saving your login session between visits, remembering your display preferences, tracking your use of the website, and for audience measurement purposes.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
The data we collect
Personal data. This is information that lets us know who you are. This includes the information you provide us when registering to use the platform (i.e. your name, company name, email address, postal address, other contact information you share with us, associated domain name and credit card information). Your login credentials are also personal data. This category also includes information tied to your identity that you provide us through other means, such as emails to our support team.
Non-personal data. This is information that doesn’t let us determine your identity. This generally comes from your use of the services after registering on our website. Non-personal data includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregation) any personal data.
In addition, and in the context of using our services, namely creating and sending emails, we have access to the information contained in the subject and content of the emails that you send out, as well as the email contacts you send to via our services.
The data you submit should not include any sensitive personal data, such as Government identifiers (i.e. social security, driving lisence, or taxpayer identification numbers), complete credit card or complete personal bank card numbers, medical records or particulars connected with applications for care or treatment associated with private individuals.
How we use your data
For visitors of our website, we use their personal and non-personal data to engage with them and support live chat conversations on the website.
We used the information we collect to provide customers information they request. As part of that purpose, we use their data:
- to create and maintain a platform account, and to control access to it;
- to provide our services and facilitate performance, including verifications relating to you and for email verifications;
- to provide real-time logs of use of the platform;
- to respond to any requests submitted for support or sales information, or similar communications;
- to communicate our services (for example through newsletters, marketing emails, announcements or special offers);
- for billing and collection purposes, for those who have subscribed to one of our paid plans;
- for the investigation, prevention and management of fraud and for breaches of our Terms of service;
- to enable third parties to provide services to us;
- for customers that request allocated dedicated IP addresses, for the purposes of assigning the dedicated IP address to that customer;
- personalize, assess, and improve our services, content and materials and for audience measurement purposes;
- to comply with applicable laws to which we are subject.
We may use your non-personal data to enhance the services, for instance through web analytics or troubleshooting. We may also use aggregated or depersonalized information to promote our services, such as by citing usage statistics.
Purpose and legal basis for collecting your personal data
We collect your personal data because we need it to perform a contract we have signed with you or because you have taken steps to enter into a contract with us (for instance, when you fill in a contact form to request information about our services or when you sign up for an account). Otherwise, we collect personal data based on your consent for that specific purpose, and in limited purposes under legitimate interests (for example, to enable us to foster and develop our relationship (with the use of a customer relationship management system), and to perform credit checks or for verification of data and payment details).
Who we share your data with
Except for the limited circumstances we describe here or in an applicable agreement or our Terms of service, we do not share your personal data with third parties. When we need to provide your personal data to third parties, we will only share it to the extent necessary to provide you with our services, and we ensure that we have in place data protection requirements with these third parties (including standard contractual clauses as well as the requisite technical and organizational measures).
We may also share your personal data as required or permitted by law and as to optimally provide our services through third party providers as described below.
Hosting Services: We host the website and operate the platform using third parties, including Google Cloud Platform, AWS® and Rackspace® (for our Mailjet and Mailgun products) and MacStadium, AWS® and Rackspace®, and Cyxtera (for our Email On Acid product). Your platform will be hosted from their data centers throughout the United States or Europe, based on where you have selected to deploy our services (no transfers between these separate data center locations occur).
Payment Providers: We use Stripe®, Chargify, Aria, and Authorize.net to process subscription payments, and therefore provide them with the personal data required to charge your credit card and maintain any payment mandate information as law requires.
Website functionalities and optimization: We may use third-party services either embedded into our website (such as Drift, Optimizely, VWO, Segment™, Split.io and Google® Analytics) or outside of it (such as GitHub®, Unbounce and Twitter®) to communicate with you or to enhance the function of the website and the services, and for product development and optimization.
Customer engagement: We use third-party service providers and platforms (such as Gainsight, Go High Level, Customer.io, Looker, Snowflake, Salesforce, Uservoice, Zapier, and Zendesk) for customer engagement, customer chat, product feedback and customer support ticketing.
IP addresses: We may share your contact information with ARIN (American Registry for Internet Numbers) for the purposes of fulfilling your request to re-assign the dedicated IP addresses.
While we provide these third parties with no more information than what is necessary to enable them to provide the services to us, any information that you provide these services providers independently is subject to their respective privacy policies and practices.
In no case do we sell, share or rent out your contacts to third parties, nor use them for any purpose other than those set forth in this policy.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities or regulatory bodies, including to meet law enforcement requirements, in the case of a court order, a summons to appear in court or any other similar requisition from a government or the judiciary, or to establish or defend a legal application.
Additionally, we will provide information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
How long we retain your data
We keep your personal data for as long as is necessary to provide our services to you (unless otherwise required by law).
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
How we transfer your data
The Attitude Is Everything Foundation, Inc. complies with the European General Data Protection Regulation 2016/679 (GDPR) as well as all applicable data protection laws. For all transfers of personal data from the EU and EEA, we maintain EU Standard contractual clauses where necessary, ensure additional safeguards such as data encryption and data minimization, as well as perform transfer impact assessments, audits and controls on our important sub processors.
Your rights in connection with your personal data
In accordance with Data Protection laws, you have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no legitimate reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Withdraw your consent and opt-out from our communications. We will honor your opt-out within 14 days. Please note that you cannot unsubscribe from service-related messages if you remain a customer.
- Object to processing of your personal data, for example, if we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data (right to data portability).
If you want to exercise any of the above rights, please email our privacy team at firstname.lastname@example.org The Attitude Is Everything Foundation, Inc. commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints should first contact our Data Protection Officer at email@example.com
The Attitude Is Everything Foundation, Inc. has also committed to cooperate with the panel established by the EU data protection authorities with regard to unresolved complaints concerning personal data transferred from the EU.
If you are located in the EU, you also have the right to lodge a complaint to your data protection authority.
The security and integrity of your personal information is very important to us. We follow industry accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We ensure the appropriate electronic, physical and managerial procedures are in place with a view to safeguarding and preserving all the data handled. Our infrastructure is located in top-tier data centers. Each of these locations adhere to strict physical and procedural controls.
Remember, though, that some parts of the services are public and that email, by its nature, is not a reliably private means of communication. If you voluntarily provide personal data in a public area of the website, unrelated parties online will be able to view it and collect it. If you don’t want to make this information publicly available, you shouldn’t post it.