Privacy policy

PRIVACY POLICY

 

Effective Date: November 16, 2019.  

 

1.       Introduction and Overview. 

This Privacy Policy provides a comprehensive description of how Intrvyl LLC (“Intrvyl,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices regarding such information. It applies to any online location that links to this Privacy Policy (the “Service”).  

By using the Service or interacting with us offline, you agree to our Terms of Use and consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

 If you are a California resident or data subject in Europe, please see the “Additional Disclosures for California Residents” and “Additional Disclosures for Data Subjects in Europe” sections. 

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.

2.       Information Collection.

        A.       Information You Provide. 

We collect information about you when you use the Service or interact with us offline, including information you provide when you register an account, update your profile, access our content, make a purchase, or contact customer support. 

The information we collect includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. The categories of information we collect, which includes the kinds of information we have collected in the last 12 months, include the following:

  • Contact Data, including your first and last name, email address, postal address, and phone number.
  • Account Credentials, including your username, password, password hints, and information for authentication and account access. 
  • Demographic Data, including your age, gender, and country. 
  • Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
  • Content, including content within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service (such as in product reviews or blog comments). 

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.  

         B.       Information Collected Automatically.

In addition, we automatically collect information when you use the Service. The categories of information we have automatically collected in the last 12 months include the following:

  • Service Use Data, including data about the features you use, the pages you visit, the emails and advertisements you view, the products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
  • Device Connectivity and Configuration Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id (e.g., IDFA or AAID).

  • Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).

    We use various current – and later – developed tracking technologies to automatically collect information when you use the Service, including the following:

    • Log Files, which are files that record events that occur in connection with your use of the Service. 
    • Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
    • Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.  

    For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

           C.       Information from Other Sources.

    We also collect information from other sources. The categories of other sources from which we have collected information in the last 12 months include the following:

    • Social networks when you engage with our content, reference our Service, or grant us permission to access information from the social networks.
    • Publicly-available sources, including data in the public domain.

    3.       Use of Information.

    We collect and use information for business purposes in accordance with the practices described in this Privacy Policy. Our business and commercial purposes for using information, including but not limited to in the last 12 months, include the following:

    • Operate and manage our Service.
    • Perform services requested by you, such as respond to your comments, questions, and requests, and provide customer service 
    • Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
    • Preventing and addressing fraud, breach of policies or terms, and threats or harm. 
    • Monitoring and analysing trends, usage, and activities.
    • Conducting research, including focus groups and surveys. 
    • Improving the Service or other Intrvyl websites, apps, marketing, products and services.
    • Developing and sending you direct marketing, including ads and communications about our and other entities’ products, offers, promotions, rewards, events, and services. 
    • Sending you advertising.
    • Fulfilling other business or commercial purposes at your direction or with your consent. 

    Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.


    4.       Sharing of Information.

    We share information we collect in accordance with the practices described in this Privacy Policy. The categories of entities to whom we disclose information, including in the last 12 months, include the following: 

    • Service Providers. We share information with entities that process the information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
    • Vendors. We share information with vendors, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Advertising and Analytics” section below. 
    • Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business. 
    • Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else. 
    • Facilitating Requests. We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Service. 
    • Consent. We share information with notice to you and your consent. 

    Intrvyl does not generally sell information as the term “sell” is traditionally understood. However, to the extent the California Consumer Privacy Act is interpreted to include advertising technology activities such as those disclosed in the “Analytics and Advertising” section as a “sale,” we will comply with applicable law as to such activity. 

    Intrvyl discloses the following categories of personal information for commercial purposes, including in the last 12 months: contact information and identifiers such as cookies, demographic information, service use data, internet or other electronic network activity information such as IP address, and profile information such as inferences. California residents should review the “Additional Disclosures for California Residents” section to learn how to opt out.  

    Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

     
    5.       Social Media and Technology Integrations.

    • Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. 
    • Brand Pages. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Intrvyl in a tweet or post), we may use your reference on or in connection with our Service.

    Please note that when you interact with other entities, including when you leave our Service, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.


    6.           Analytics and Advertising.

    We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services. 

    As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

    As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

    For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
     

    7.       Your Rights and Choices.  

            A.       Account Information.

    You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 

            B.       Tracking Technology Choices.

    • Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. 
    • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com. 

    Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly. 

           C.       Analytics and Interest-Based Advertising.

    Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .  

    The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

    To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out. 

    You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).  

    Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any Intrvyl statements regarding their opt out options or programs.


            D.       E-mail Communications.

    You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or Intrvyl’s ongoing business relations.

    Please note that your opt-out is limited to the email address and device used and will not affect subsequent subscriptions.  

            E.       Your California Privacy Rights.

    California residents have additional rights as set out in the “Additional Disclosures for California Residents” section below.
     

           F.       Your European Privacy Rights. 

    Data subjects in Europe have additional rights as set out in the “Additional Disclosures for Data Subjects in Europe” section below. 

    8.       Children.

    The Service is intended for a general audience, and is not directed at children under (13) years of age. 

    We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at privacy@beatoeartraining.com. We will remove the data to the extent required by applicable laws. 

    In California, we do not knowingly “sell” the personal information of minors under 16 years old.  

    If you are a California resident under 18 years old and you are registered with a Service, you can ask us to remove content or information you have posted to a Service. Email us at privacy@beatoeartraining.com with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. 


    9.            Data Security.

    We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. 


    10.       International Transfer.

    We are based in the U.S. and the information we collect is governed by U.S. law.  If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. 


    11.       Changes to this Privacy Policy.

    We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.  

     
    12.       Contact Us.

    If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

    By email: 

    privacy@beatoeartraining.com

    By mail:

    Intrvyl LLC

    289 S Culver St

    Lawrenceville, GA 30046

    If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us and we will be happy to assist you. 


    13.       Additional Disclosures for California Residents.

           A.        Right to Know and Delete.      

    If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us: 

    • The categories of personal information we have collected about you;  
    • The categories of sources from which the personal information was collected; 
    • The categories of personal information about you we disclosed for a business purpose or sold; 
    • The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and 
    • The business or commercial purpose for collecting or selling the personal information.

    You also have the right to request the specific pieces of personal information we have collected about you.  

    In addition, you have the right to delete the personal information we have collected from you.

    To exercise any of these rights, please submit a request through our online form available in your password-protected account, or email us at privacy@beatoeartraining.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

            B.           Do Not Sell My Personal Information. 

    To the extent Intrvyl sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information or emailing us at privacy@beatoeartraining.com. 

            C.       Authorized Agent.  

    You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly. 

            D.       Right to Non-Discrimination. 

    You have the right not to receive discriminatory treatment by us for the exercise of any your rights. 

            E.       Shine the Light. 

    Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. 


    14.       Additional Disclosures for Data Subjects in Europe.

            A.           Roles.

    Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Intrvyl acts as a controller with respect to personal data collected as you interact with our Service, websites, emails, and advertisements.  

            B.       Lawful Basis for Processing.

    Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a another party, and your interests and fundamental rights and freedoms do not override those interests. 

            C.       Your Data Subject Rights.

    If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

    You may exercise your rights by submitting a written request to us at the address set out in the “Contact Us” section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.  

    Please note that we retain information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. 

            D.       Complaints.

    If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us at privacy@beatoeartraining.com.