PRIVACY POLICY
Last updated December 18, 2020
Thank you for choosing to be part of our community at Jim Hjort dba Right Life Project (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at admin@jimhjort.com.
When you visit our website https://www.jimhjort.com and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.
This privacy policy applies to all information collected through our website (such as https://www.jimhjort.com), any other subdomains, media form, media channel, mobile website, or mobile application related, linked, or otherwise connected thereto (collectively, the “Site”), and/or any related online or live courses, workshops, presentations, trainings, events, coaching services, or other services (collectively, the “Services“).
Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.
WHAT INFORMATION DO WE COLLECT?
Personal Information You Disclose to Us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, joining our email list (including by providing your email address in exchange for content), registering for Services, participating in activities related to the Services, or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us, the choices you make, and the Services, and features you use. The personal information we collect can include the following:
Publicly Available Personal Information
We collect first name, last name, email addresses, phone numbers, and other similar data.
Personal Information Provided by You
We collect data collected from surveys; financial information (credit card number, purchase history, invoices); and other similar data.
Payment Data
We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy policy here: https://stripe.com/privacy.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information Automatically Collected
In Short: Some information—such as IP address and/or browser and device characteristics—is collected automatically when you visit our Services.
We automatically collect certain information when you visit the Site and use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device type and name, country, location, information about how and when you use our Products and Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
We also collect information about tools and protocols, such as IP (Internet Protocol) addresses; cookie identifiers, or others such as the ones used for analytics and marketing; device’s geolocation; and other similar data. See (“DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” below.)
HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Site for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, such as to provide you with information or Services you have requested; to enter into or perform a contract with you, with your consent; to contact you in connection with the above interests; and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and login process: If you create an account with us in order to receive information or Services, we use the information you provide to facilitate account creation and logon process for the performance of the contract.
To send you marketing and promotional communications: We may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see “WHAT ARE YOUR PRIVACY RIGHTS” below).
To send administrative information to you: We may use your personal information to send you new Services feature information and/or information about changes to our terms, conditions, and policies.
To post testimonials: We post testimonials about our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name, likeness, and testimonial. If you wish to update or delete your testimonial, please contact us at admin@jimhjort.com and be sure to include your name, testimonial location, and contact information.
To deliver targeted advertising to you: We may use your information to develop and display content, Services, and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
To administer prize draws and competitions: We may use your information to administer prize draws and competitions when you elect to participate in competitions.
To request feedback: We may use your information to request feedback and to contact you about your use of our Services, including by conducting surveys.
To protect our Services: We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
To enable user-to-user communications: We may use your information in order to enable user-to-user communications with each user’s consent.
To enforce our terms, conditions and policies for business, legal, and contractual purposes:
To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To manage user accounts: We may use your information for the purposes of managing our account and keeping it in working order.
To deliver Services to the user: We may use your information to provide you with the requested Services.
To respond to user inquiries/offer support to users: We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
For other business purposes: We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services and marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, consultants and other third-party service providers: We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, email delivery, hosting services, and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity, or advertise to you. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.
Business transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following third parties.
We only share and disclose your information to the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
Advertising, Direct Marketing, and Lead Generation
Google AdSense
Invoice and Billing
Stripe
Retargeting Platforms
Google Ads Remarketing, Facebook
Social Media Sharing and Advertising
Facebook social plugins, Instagram social plugins, Twitter social plugins, LinkedIn social plugins, and Pinterest social plugins
Web and Mobile Analytics
Google Analytics
Website Hosting
Squarespace, Kartra
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
Like many businesses, we collect information through tools like cookies, web beacons, analytics services, advertising providers, and similar technologies and services to gather data about you or your computer location. We may use this statistical data for statistical analysis, marketing, advertising, or similar promotional purposes. This data is often tracked by us or our technology services provider by using “cookies” or “pixels” during your visit. A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the server that gave it to you. It functions as your identification card and enables us to record your passwords, purchases, and preferences and to deliver targeted messages or advertising to you in the future. It cannot be executed as code or deliver viruses. Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. For some web pages that require an authorization, cookies are not optional. Users choosing not to accept cookies will probably not be able to access those pages.
We also use Facebook “pixels” on the Site so that we can understand your digital behavior and potentially later target you with related advertising. We also use Google Analytics to understand how long you might spend on the Site or how you interact with the Site.
If you ever choose to opt out of targeted advertising with us, then please contact us at admin@jimhjort.com so that we can remove your email from any advertising we may use. Please note that this may result in you being unable to receive or access content or Services that you had previously requested.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in United States. If you are accessing our Services from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties in other countries with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above).
If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.
European Commission’s Standard Contractual Clauses
Such measures implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 90 days past the start of idle period on the user’s account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at admin@jimhjort.com.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/board/members_en.
If you have questions or comments about your privacy rights, you may email us at admin@jimhjort.com.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
Log into your account settings and update your user account, if applicable.
Contact us using the contact information provided at https://www.jimhjort.com/contact.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements. Also, please note that terminating your account may result in you being unable to receive or access content or Services that you had previously requested or paid for.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of, or access to, our Services. For further information, please see “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” above.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link at the bottom of the emails that we send, or by contacting us using the details provided below. You will then be removed from the marketing email list. However, please note that taking this action may result in you being unable to receive or access content that you had previously requested. However, we will still need to send you service-related emails that are necessary for the administration and use of your account, so that you may retain use of Services you may have paid for. To otherwise opt-out, you may:
Note your preferences when you register an account with the site;
Access your account settings and update your preferences; or
Contact us using the contact information provided.
DATA BREACH
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when we believe you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that we become aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information, we will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this privacy policy from time to time. The updated version will be indicated by a revised “Last updated” date, and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Jim Hjort, by email at admin@jimhjort.com, or by post to:
Jim Hjort dba Right Life Project
Attn: Data Protection Officer
10921 Wilshire Boulevard
Suite 508
Los Angeles, CA 90024
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us using the information above, and we will respond to your request within 30 days.
