Online Privacy Policy

General Data Protection Regulation Compliant

Updated August 2018

This privacy policy outlines what information (“PERSONAL DATA”) is collected from you (“SUBSCRIBER”) and how that information is handled by Victory in Action LLC (the “COMPANY”, “we”, “us”, “our”). PERSONAL DATA is any personally identifiable information, information that specifically identifies you (name, email address, ship to/bill to address, phone number) and can be used to specifically locate you from within the COMPANY’S database and or filing system. All is done in accordance with the recent General Data Protection Regulation (GDPR).

The COMPANY respects the privacy concerns of the users of all its owned, hosted, or operated websites, www.victoryinaction.com, www.deborahshowell.com, www.emotionalmusclefitness.com, www.inspiredmedicalwarrior.com, inspiredhealthcarewarrior.com, www.medicallifecoach.net, www.healthcarerebootcamp.com and any other site that we have owned or operated, do own and operate or may own or operate in the future including social media sites (collectively, the “SITES”) and the services and or goods provided there (the “SITES”). Unless we say otherwise, all references to the SITES in this Privacy Policy include all such SITES. This Privacy Policy terms of use does not apply to your use of unaffiliated Sites to which any of the SITES may link to or direct you to.

Summary: The COMPANY provides various ways for you to add your personal information to our database. By clicking on “Submit”, “Sign-up”, “Buy now”, “Purchase”, and or any other button (or functionality) that has a similar meaning you are providing your explicit consent to be added to the COMPANY’s communication system. The COMPANY outlines below the methods of communicating with you based on the information you provide. You may opt-out of this at any time by clicking on the “unsubscribe” button included on all email, messenger, and or currently available means communication that the COMPANY has described below it may use to communicate with you.

Please also review the Terms of Use here which also govern your use of this SITE.

You can unsubscribe from any of our emails at any time with the unsubscribe link at the bottom of the email you receive from the COMPANY.

USE OF INFORMATION

You can visit our SITES without telling us who you are or revealing any PERSONAL DATA. ANY PERSONAL DATA COLLECTED BY THE SITE MUST BE VOLUNTARILY ENTERED BY THE SUBSCRIBER. However, certain non-personal information is recorded by the standard operation of the COMPANY’s internet servers, such as Google Analytics. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.

 

This Privacy Policy (together with the COMPANY Terms of Use and any other policies referenced) identifies how the COMPANY will collect and use any personally identifiable information, such as your name, email, address, financial account information, or other information that you provide to the COMPANY during your visit to the any of the SITES.

By providing your PERSONAL DATA to the COMPANY in any format and/or continuing to use any of our services or visiting our SITES you accept and consent to the practices described in this Privacy Policy and Information Notice.

As the COMPANY services evolve and we perceive the need or desirability of using your PERSONAL DATA collected in other ways, we may from time to time amend this Privacy Policy. The effective date appears at the beginning and end of this Privacy Policy. The COMPANY encourages you to check our SITES frequently to review the current Privacy Policy in effect and any changes that may have been made and updated.

Information you as the SUBSCRIBER give us

When you contact the COMPANY through any of our SITES, or by corresponding with the COMPANY by phone, e-mail, or otherwise, or in-person at an event, the COMPANY may collect PERSONAL DATA including:

• contact information, such as name, address, email, and phone;
• financial information, such as credit card and account information collected when you purchase products or services;
• personal information about your goals and aspirations for our products, services, and live events;

The SITES various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give the COMPANY contact information such as your:

• Name,
• Email,
• Profession

Information submitted at the time of submission will be used by the COMPANY to:

• Provide SUBSCRIBER the requested information, products, and or services from the COMPANY;
• Carry out our obligations arising from any contracts entered into between you and the COMPANY;
• Provide SUBSCRIBER access to the requested content from the COMPANY;
• Email SUBSCRIBER a (daily/weekly/monthly) information updates or newsletter from the COMPANY;
• Contact you in the future to provide you with information about other goods and services the COMPANY offers;
• Notify you about changes to our service;
• Comply with applicable laws and regulations;
• Record details about the products and services you order from the COMPANY for training purposes and for quality assurance;
• Perform data analyses (including anonymization and aggregation of PERSONAL DATA);

PERSONAL DATA submitted voluntarily by the SUBSCRIBER is held:

• On COMPANY servers or on servers provided by cloud service providers, Calendly scheduler site, within the COMPANY’S Kajabi SITE and database;
• Until the SUBSCRIBER requests to be unsubscribed and or up to five years from the time of submitting, whichever comes sooner. Before removal, the COMPANY will ask SUBSCRIBER to confirm that he or she wants to remain within the database.

As the SUBSCRIBER:

• Security for all personally identifiable information is extremely important to us. By submitting your PERSONAL DATA, you agree to this transfer, storing, and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. You acknowledge that the transmission of information via the Internet is not completely secure. Although the COMPANY will do our best to protect your PERSONAL DATA, the COMPANY cannot guarantee the security of your data transmitted to our SITES; any transmission is at your own risk.

LEGAL BASIS FOR USE OF INFORMATION

The COMPANY is legally processing SUBSCRIBER’S PERSONAL DATA based on the following:

• The SUBSCRIBER has given his or her explicit and voluntary consent to the COMPANY;
• The SUBSCRIBER has a contract with the COMPANY that necessitates the COMPANY having his or her PERSONAL DATA;
• The COMPANY has a legitimate interest to process SUBSCRIBER’S PERSONAL DATA;
• The COMPANY has a legal obligation that requires processing SUBSCRIBER’S PERSONAL DATA;

USE TO THIRD PARTIES

The COMPANY does not sell or lease your PERSONAL DATA to any third parties. We may partner with third parties to provide some of the content, services, and products available on our SITES and at our events. Brands of our provider partner/s may appear on the SITES in connection with such content, products and or services. The COMPANY may share with provider partners any information you provide, or that is collected, while visiting any pages that are made available in cooperation with our provider partner. In some cases, the provider partner may collect information from you directly, in which cases the privacy policy of the provider partner may apply to the provider partner’s use of your information. The privacy policy of our provider partners may differ from the COMPANY. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.

USE OF CREDIT CARD INFORMATION

The COMPANY does not store any credit card information it may receive regarding a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.

All credit card information is handled by PayPal and or Stripe.

USE LEGAL OBLIGATIONS

The COMPANY may disclose SUBSCRIBER information in special cases when required by legal and or law enforcement and only when required by law.

If the COMPANY has reasonable reason(s) to believe that disclosing PERSONAL DATA held by the COMPANY is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the COMPANY’S rights or property, other users of the SITES, and or anyone else that could be harmed by such activities, then the COMPANY will work with the appropriate and legitimate law enforcement and or legal authorities to make sure that the PERSONAL DATA is handled in accordance with the applicable laws.

SUBSCRIBERS RIGHTS

As a subscriber and or user of the SITE, you have the following rights:

• Transparent information from the COMPANY regarding how they communicate and interact with the SUBSCRIBER;
• The right to hear back from the COMPANY regarding any inquiry into SUBSCRIBER’S PERSONAL DATA;
• To request correction of PERSONAL DATA from the COMPANY;
• Access to SUBSCRIBER’S PERSONAL DATA including knowing the purposes that the data is used for;
• To request erasure from the COMPANY’S records provided that there are not overriding legal, public interest, or legitimate interests;
• To a restriction on the processing of the PERSONAL DATA;
• To object to processing of PERSONAL DATA – the COMPANY shall no longer process the SUBSCRIBER’S PERSONAL DATA unless the COMPANY demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the SUBSCRIBER or for the establishment, exercise or defense of legal claims.
• To file a complaint with the supervisory authority;
• The right to unsubscribe at any time (withdraw consent)

CHILDREN UNDER AGE 13

The COMPANY recognizes the special obligation to protect PERSONAL DATA obtained from children age 13 and under.

IF YOU ARE 13 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY.

If the COMPANY discovers that a child age 13 or younger has signed up on the SITE and or provided the COMPANY with PERSONAL DATA, the COMPANY will delete that child’s PERSONAL DATA from our records.

The COMPANY nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:

1. Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
2. Know the sites your kids are visiting and which sites are appropriate.
3. Look for Website privacy policies. Know how your child’s information is treated.
4. Check out the Federal Trade Commission’s (FTC) site for more tips on protecting children’s privacy online.

USE OF COOKIES

Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using the COMPANY’S SITE easier by saving your passwords and preferences for you.

These cookies are restricted for use only on COMPANY’S SITE, and do not transfer any PERSONAL DATA to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions.

If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the SITE may not function properly or may be considerably slower.

The COMPANY uses the following cookies on the SITE – see our Cookie Policy Below.

MALWARE/SPYWARE/VIRUSES

Neither the COMPANY nor the SITES knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

LINKS TO EXTERNAL SITES

The COMPANY’S SITES may contain links to other websites that may offer products or services that you might find useful. These sites may request information from you when you arrive. In such instances, the collection and use of your personal information will be governed by the privacy policy applicable to the individual site. The COMPANY does not control the privacy policies, contents, or links that appear on those sites.

The COMPANY is not responsible for the content or practices of third party websites that may be linked to the SITES. The COMPANY is not responsible for any information that you might share with such linked websites.

You should refer to each website’s respective privacy policy and practices prior to disclosing any information. We encourage you to review the privacy policies and terms and conditions of any third-party sites or services before providing any of them with your personal information.

BULLETIN BOARDS AND CHAT AREAS

Guests of the SITES are solely responsible for the content of messages they post on the COMPANY’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.

OPT OUT OR REMOVAL OF YOUR INFORMATION

The SITE provides the SUBSCRIBER the opportunity to opt-in to receive communications from the COMPANY at the point(s) where PERSONAL DATA information is required to be voluntarily entered by the SUBSCRIBER.

The SUBSCRIBER always has the option of removing their PERSONAL DATA from any communications list in order to discontinue any such future communications.

In order to ensure removal from any list, please follow the specific instructions set forth within the communications you receive from the COMPANY, which you no longer wish to receive.

If you are unsuccessful in completing the instructions specified in any such communication, please email the COMPANY at deborah@victoryinaction.com  and simply request to unsubscribe.

• Unsubscribe from all communications from the COMPANY
• Unsubscribe from a specific set of communications from the COMPANY

CONTACT INFORMATION

If you have any complaints or concerns about the COMPANY or about this privacy statement, please contact:

Via email: deborah@victoryinaction.com

or

Via regular mail: please contact the COMPANY for the current mailing address.

Information provided by you via general email inquiries to the COMPANY such as your email address is used only to respond to your inquiries in the ordinary course of business and is never shared with third parties.

SECURITY

Security for all PERSONAL DATA is extremely important to the COMPANY.

Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure.

As a result, while the COMPANY strives to protect SUBSCRIBER’S PERSONAL DATA, the COMPANY cannot ensure or warrant the security of any PERSONAL DATA the SUBSCRIBER transmits via the internet. By transmitting any such information to the COMPANY, SUBSCRIBER accepts that he or she does so at their own risk.

TRANSFER OF CUSTOMER INFORMATION

Customer lists and information are properly considered assets of a business. If COMPANY merges with another entity, or if it sells its assets to another entity, the COMPANY’S customer list and information would be included among the assets transferred.

• SUBSCRIBER would be given the opportunity to unsubscribe both before and after the sale.

YOUR ACCEPTANCE OF THESE TERMS

By using the SITE, the SUBSCRIBER accepts the policies and restrictions set forth in this Online Privacy Policy. If you do not agree to this policy, please do not use the SITE. This Online Privacy Policy may be revised from time to time by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Online Privacy Policy to which you are bound.

 

 

DISCLAIMERS

LIVE STREAMING

If you participate in any live streaming activities with the COMPANY through third party providers, you are providing your consent for COMPANY to record and reuse the live streaming material at COMPANY’S sole discretion, including but not limited to, educational and marketing purposes, recorded videos (paid and unpaid), blog posts, and any other form of audio visual currently in operation (or yet to reach the market).

COMPANY in no way is obligated to compensate you for any portion of a comment, image, social proof, that you provide as part of your voluntary participation in live streaming platforms.

THE SITE DOES NOT PROVIDE BUSINESS ADVICE

The information contained in this SITE is for general information purposes only. While COMPANY strives to keep the information up to date and correct, COMPANY makes no representations or warranties of any kind express or implied, about the completeness, accuracy, reliability, suitability, or availability with respect to the SITE or the information products, services, or related graphics contained on the SITE for any purpose. Any reliance you place on such information is strictly at your own risk.

Using this SITE does not establish a coach-client relationship with Deborah Howell (“I”, “me”) or with the COMPANY, or its licensors. This SITE does not direct decision making on your behalf or on behalf of your business. Any business decisions you make as a result of information posted on this site, products sold through this site, or links listed on this SITE are your sold responsibility.

THE SITE DOES NOT PROVIDE MEDICAL OR LEGAL ADVICE

The Company publishes this website and its blogs to inform customers, visitors, and users about what it offers. The website and blogs are not intended as medical or legal advice on any matter. You should not act or refrain from acting because of information found here without first seeking appropriate medical, legal or other professional advice from someone who is familiar with your circumstance.

In the operation of this web site and our blogs, a coach-client relationship is not created by your use of this website. Such a relationship can only be established to the extent that I expressly agree to the relationship. Please do not communicate any information you regard as confidential unless and until we have established a formal coach-client relationship and or agreement.  Any information you send to me before we establish a coach-client relationship may not be privileged or confidential. Information you send to the COMPANY over the Internet may not be secure.

I make no representations, endorsements or warranties, express or implied, regarding any information that appears on this website, in my blog or on any third-party site linked to this website.

COOKIE POLICY

OUR COOKIE POLICY Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

COOKIES WE MAY USE

Cookie: Universal Analytics (Google)
Purpose: These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.
Learn More: Read Google’s overview of privacy and safeguarding data

Cookie: YouTube
Purpose: We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.
Learn More: YouTube embedding video page

Cookie: Facebook Ads conversion tracking (Facebook, Inc.)
Purpose: Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Cookie: Facebook Custom Audience (Facebook, Inc.)
Purpose: Facebook Custom Audience is a Remarketing and Behavioral Targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and email address.
Place of processing: US – Privacy Policy – Opt Out.

Cookie: Google Analytics with anonymized IP (Google Inc.)
Purpose: Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.

Cookie: Kajabi

_kjb_session	Kajabi session cookie	Tracks your active admin session so you don’t need to re-login
kjba	Kajabi affiliate token	Tracks which affiliate has referred an offer purchase
_abv	Admin bar hidden	Tracks whether the user wishes their admin previewing bar to be hidden

DISABLE COOKIES

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org. Below you’ll find the cookies that are in use on this site.

Find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

To find information relating to other browsers, visit the browser developer’s website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.