First to set your mind at ease we never sell, give or lend your information to others for marketing. Below describes what information is collected in the course of normal business and how we use it. Some of it is in legal terminology as required by law but if you have any questions please contact us at the contact information below. We respects your privacy and are committed to protecting your personal data.
Also see our Terms of Service here: http://international.espavo.org/terms-of-service-espavo/
You may request to be removed from our e-mail list at any time. We have several lists to send different languages and preferences so the best place to remove yourself from our list is at the bottom of the e-mail we send to you. If you can not find your e-mail please contact Webmaster@espavo.org and ask for removal
If you wish you may also be removed from our membership site but be aware that doing so will remove your access to any and all products you may have registered for or purchased. Removal from membership can be done by e-mailing your request to Webmaster@espavo.org and specify you wishes.
It also tells you about your privacy rights and how the law protects you.
We reserve the right to change this policy at any time so please check back at http://international.espavo.org/privacy-policy/ to see if any changes have been made.
2. Our website
Our websites at Espavo.org, all of associated subdomains and Paths2Empowerment.com sell audio and videoseminars and coaching services which are aimed at business users – individuals and companies. This website is not intended for children and we do not knowingly collect data relating to children.
Espavo is a legal 501(c)(3) Corporation legislated by a board of Directors:
- Espavo. PO Box 34838, Las Vegas, NV 89133 USA, and is the data controller responsible for this website and any handling of personal data carried out by or on behalf of Espavo.
3. Personal data which we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect a variety of information about our wonderful customers (you!) and visitors to the our websites. This personal data falls into these categories:
Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
Contact Data includes billing address, delivery address, e-mail address and telephone numbers.
Financial Data includes payment card partial details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services.
Tracking Data includes information we, or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
Marketing and Communications Data includes your preferences in receiving direct marketing from us, and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and bio-metric data.)
Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, email or through chat or social media.
This includes personal data you provide when you:
- sign up for our mailing list.
- make inquiries or request information be sent to you;
- create an account on our website;
- order our products or services;
- ask for marketing to be sent to you;
- engage with us on social media;
- enter a competition, promotion or survey;
- contact customer service; or
- request help by filling out a help desk ticket.
- placing your name and e-mail on our list at the end of videos on Vimeo.
- leave comments or reviews on our products or services.
Automated technologies or interactions
As you interact with us, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on social media).
Third parties or publicly available sources
We may receive personal data about you from various types of third parties, including:
- Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;
- Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
How we use your personal data
- Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.
- Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.
5. Advertising, marketing and your communications preferences
We send the Soul Shifting, Sacred Connecting Newsletter to you if you have opted in to receive it. On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to the Newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out The easiest way to opt out is to use the unsubscribe link at the bottom of the communication. (But we’d be really sorry to see you go.)
Cookies are a tool that we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used, generally, they are pretty clever.
Cookies help us work better and provide lots of help in the background to make the process of being a customer a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page, and things staying in your cart while you go off and look at other pages.
There are also cookies that allow us to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.
When you use our sites, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It’s important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
7. Disclosures of your personal data
We may share personal data with the following categories third parties:
- Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
- Auditors and professional advisers like bankers, lawyers, accountants and insurers; and
- Government, regulators and law enforcement.
8. Payment information
Espavo.org, Europe.espavo.org and Paths2Empowerment.com use third party payment processor PayPal to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors – Espavo never sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.
We only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.
9. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Data retention
We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
11. Your legal rights
If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:
- The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
- The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
- The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
- The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
- The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
- The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
- Rights in relation to automated decision-making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision-making.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. How to contact Espavo about privacy