What information do we collect and how is it used?
Information You Voluntarily Submit to the Website
The Website may collect personal information from you such as your name or email address. For example, you may voluntarily submit information to the Website by leaving a comment, subscribing to a newsletter, or submitting a contact form. Personal Data may include, but is not limited to, your name, email address and phone number.
Our legal basis for processing this information is your consent, and by voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred and stored from your current location to the offices and servers of Live Bravely and the authorized third parties referenced below.
Information We Collect from Others
The Website may receive information about you from other sources. For example, if you use a third-party software through the site, they may transfer information to us for fulfillment. We do not control the data privacy or protection policies of third parties, and we are not responsible for the privacy practices of these third parties. Our legal basis for processing this information is our legitimate interests, namely monitoring and improving our services, and the legitimate interests of our customers.
Automatically-Collected Information
The Website automatically collects certain information about you and the device with which you access the Website. For example, when you use the Website, The Website will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. The Website may also collect information about actions you take when using the Website, such as links clicked.
Cookies
The Website may log information using cookies, which are small data files stored on your browser by the Website. The Website may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.
How Your Information May Be Used
The Website may use the information collected in the following ways:
To operate and maintain the Website;
To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
To respond to your comments or inquiries;
To provide you with user support;
To track and measure advertising on the Website; or,
To protect, investigate, and deter against unauthorized or illegal activity.
Legal Bases for Processing Data Under the General Data Protection Regulation (“GDPR”)
Below are the types of lawful basis that we will rely on to process your Personal Data:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected].
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
Consent means where you have consented to a certain use of your Personal Data.
Third-Party Use of Personal Information
Live Bravely may share your Personal Data with certain third as set forth below:
Third Party Vendors
We may share your information with third party vendors or service providers who help us provide the Services or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request.
Parent Companies and Affiliates
We may share your information with a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), provided that we require our Affiliates to honor this Privacy Policy.
Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Related Companies
We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.
Third Parties with Permission
We may share your information with third parties to whom you ask us to send your information.
Agents, Consultants, and Related Third Parties
Live Bravely, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements
Live Bravely may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Live Bravely, (iii) act in urgent circumstances to protect the personal safety of users of the Sites or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our Customer contracts.
The Website may share your information with third parties when you explicitly authorize us to share your information. Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The Website currently uses the following third-party service providers:
Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.
Mailchimp – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.
At this time, your personal information is not shared with any other third-party applications. This list may be amended from time to time in the Website’s sole discretion.
Except when required by law, Live Bravely will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, Live Bravely may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
Anonymous Data
From time to time, Live Bravely may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.
Cookies
The Website uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customize content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein.
Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if users deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.
Advertising
Display Ads
We may use third-party advertising companies to serve content and advertisements when you visit the Website, which may use cookies. No personally identifiable information is shared with the Website's ad providers. If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit http://www.networkadvertising.org/managing/opt_out.asp.
Retargeting Ads
From time to time, the Website may engage in remarketing efforts with third-party companies, such as Google, Facebook, or Instagram, in order to market the Website. These companies use cookies to serve ads based on someone's past visits to the Website. This means, after visiting the Website, you may see an ad for our services. However, your personally identifiable information is not used by any remarketing service other than to present you offers from Live Bravely. We use the following third-party service providers for remarketing:
Facebook: Opt-out of Facebook remarketing here
Affiliate Program Participation
The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions.
Live Bravely is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and links to Amazon.com. As part of this Amazon Associates program, the Website will post customized links, provided by Amazon, to track the referrals to their website. This program utilizes cookies to track visits for the purposes of assigning commission on these sales.
Newsletters
On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, Live Bravely may see if and when you open an email and which links within the email you click. Also, this allows Live Bravely to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.
Rights Related to Your Personal Information
Under laws in certain countries in which we operate, customers and other visitors to our Website from those countries have a right to access Personal Data about themselves, and to amend, correct or delete Personal Data that is inaccurate, incomplete or outdated. We will, upon request, provide you with confirmation regarding whether we are processing Personal Data about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your Personal Data that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request.
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.
We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
Opt-Out
If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications. You may also notify us at [email protected] to be removed from our mailing list.
Access
You request may access the personal information we have about you by submitting a request to [email protected].
Amend
You may contact us at [email protected] to amend or update your personal information.
Forget
In certain situations, you may request that we erase or forget your personal data. To do so, please submit a request to [email protected].
Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law.
Sensitive Personal Information
At no time should you submit sensitive personal information to the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. If you elect to submit such information to us, it will be subject to this Privacy Policy.
Links to Other Websites
This Privacy Policy applies only to the Website. The Website may contain links to other websites not operated or controlled by Live Bravely (the “Third-Party Sites”). The policies and procedures described here do not apply to the Third-Party Sites. The links from the Website do not imply that Live Bravely endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.
Other Terms & Conditions
Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Live Bravely. Please refer to those agreements as needed.
Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Sites, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.
Children's Information
The Website does not knowingly collect any personally identifiable information from children under the age of 16. If a parent or guardian believes that the Website has personally identifiable information of a child under the age of 16 in its database, please contact us immediately at and [email protected] we will use our best efforts to promptly remove such information from our records.
Arbitration
This Privacy Policy will be governed and construed in accordance with the laws of the State of Massachusetts. Any controversy or claim arising out of or relating to the Privacy Policy, or the breach thereof, shall be settled by arbitration administered by the American Arbitration Association ("AAA") under its Commercial Arbitration Rules, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The place of any such arbitration shall be in or near Boston, Massachusetts. The parties also agree that the AAA Optional Rules for Emergency Measures of Protection shall apply to the proceedings.
Changes to Live Bravely's Privacy Policy
The Sites may change from time to time. As a result, at times it may be necessary for Live Bravely to make changes to this Privacy Policy. Live Bravely reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Sites after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
Access to Information; Contacting Live Bravely
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services. To unsubscribe from any communications, please contact us at the email address below.
Please also feel free to contact us if you have any questions about Live Bravely's Privacy Policy or the information practices of the Services.
You may contact us as follows: [email protected].
Last updated: July 19, 2019