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Privacy Policy

Effective Date: 27/07/2020

Thank you for visiting our Privacy Policy. This Privacy Policy applies to Empowered First, subsidiary of anhae Limited, (hereafter “EF”, "We,” "Us"), respect the privacy rights of our users. EF’s websites is www.empoweredfirst.com (hereafter, the “Website”). EF’s products include one-on-one coaching and online courses on our Website (the “Products”). Collectively, the Website, and Products are referred to as the “Services.” We are committed to protecting the information collected through the Services.


By visiting and interacting with our Websites and Products, you may share certain information with us, as detailed below. We may share some of the information you share with us through our websites to provide you with the most relevant content.


We want to ensure you understand the information we collect, how we use it, how we share it, and how you can control your information. Please read our Privacy Policy in its entirety, and don't hesitate to reach out to us here if you have any questions about our privacy practices.

INTRODUCTION

This privacy policy ("Privacy Policy") explains:


  1. The types of information collected by EF and its partners through the Services and the purposes for which We use it.
  2. How EF collects, stores, and shares your information.
  3. Your rights with respect to such information collection

Your access to and use of the Services is subject to EF’s Terms of Use (the "Terms"). Any capitalized terms used, but not defined, in this Privacy Policy have the meanings provided in the Terms.


BY INSTALLING, USING, REGISTERING TO, OR OTHERWISE ACCESSING ANY SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND CONSENT TO THE COLLECTION, USE, AND PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT VISIT, INSTALL, USE, REGISTER TO, OR OTHERWISE ACCESS ANY SERVICES.


Personal Information: "Personal Information" is information that can be used either directly or indirectly to identify an individual (you). Examples include name, email address, physical address, Internet protocol (IP) address, mobile ad ID, and your interactions with the Websites that are connected to other identifying information, such as name, email address, physical address, and Internet protocol IP address.

Information we collect about you

When you use Our Services, We may automatically collect information, when:

  1. Social Media and Sharing: If you share an article or post a comment or other content with a friend/contact.
  2. Device Information: We collect information from or about the computers, phones, or other devices where you install or access Our Services, depending on the permissions you've granted.
  3. Data Analytics: Web analytics services, including third-party services such as Google Analytics, collect information about how visitors use Our Websites, on both an individual and aggregated basis (click here for more information about Google Analytics).

Marketing: We, and our marketing partners, collect information indicating an interest in particular subject matter.

The personal information we collect, when you use our Websites and Apps, typically includes attributes such as the operating system, hardware version, device settings, device identifiers, connection information (e.g. ISP), browser type, language and time zone, mobile phone number, mobile ad ID, and IP address; social signals (including, the friends/contacts content has been shared with); and, Website use information, such as pages viewed, interactions, dwell time, and navigation.


In addition to other rights detailed below, you may choose to install the Google Analytics Opt-Out Browser Add-on to opt out of Google Analytics data collection.


WHAT KINDS OF INFORMATION DO WE COLLECT?

We receive information from or about you depending on the nature of your interaction with Our Services.


Information you provide to us

You may provide us with information in several ways, including:



  1. Registering/Signing Up in the Services: When you choose to sign up for newsletters, sign up for an account, on our Services.
  2. Using our Products: When you search for and schedule coaching programs.
  3. Transactions with the Services: When you submit an opinion or comment through the Services, contact Us, or register for more information regarding products or services.
  4. Promotions: From time to time, EF may offer promotions, such as surveys or sweepstakes, on the Services, for which we need Personal Information to administer.

The Personal Information that you provide may include your name, email address, physical address, birth date, gender, zip/city, marital status, your work.


Cookies and Tracking Technologies

With appropriate consent, We use cookies (and similar technologies) to help Us collect, analyze, improve, secure, and market

Our Websites and Services, and to support functionality which enhances your browsing experience.You can read more about how and why We use cookies in our Cookies Policy (below).

HOW DO WE USE YOUR INFORMATION?

We use personal information about you in connection with the following purposes:

To Provide and Enhance the Services: We use the information We collect to deliver and enhance our services, including ensuring our content is presented in the most effective manner for your device, to personalize features and content and make suggestions for you on our Services.

Transactions: We use your Personal Information to process your transactions, to send you confirmations, to respond to your requests, and for any related communications.

Retargeting: We use your information to allow Us or third parties to deliver advertisements based on your interests on our Websites, affiliated websites or third-party sites. Our retargeting activities abide by the NAI code of conduct.

Marketing: We use the information We have to improve our advertising systems so We can show you relevant interest-based advertising and measure the effectiveness and reach of advertisements and services. We may use your Personal Information for other marketing and market research purposes to learn more about our users. We will only contact you for direct marketing purposes in accordance with applicable laws. You may opt out of our use of your Personal Information for marketing, market research, or direct marketing purposes at any time by sending a rights request as set forth in the "Your Rights" section below. Occasionally, comments may be anonymized and used in marketing materials.

Analytics: We may store details of your visits to our Websites and your electronic interactions with any emails that We send to you ("Usage Data") under a pseudonym (i.e. not under your name but under an ID number), including the pages you visited and services you used. We use such Usage Data to help Us learn more about our users' preferences, to be able to tailor our Websites according to your interests and preferences, to help Us address problems with and improve our site design, products, and services; to analyze trends and statistics; and to present content in the clearest and most friendly manner for you.

To Communicate with You: We use your information to send you marketing communications, communicate with you about our Services, and let you know about changes to our policies and Terms. We also use your information to respond to you when you contact Us. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, We will need to collect certain information about your device such as operating system and user identification information.

Other Reasons: We may use and collect Personal Information for other legitimate purposes associated with protecting your interests, Our interests and those of third parties, including, keeping Our services safe and secure, complying with the law, and when obtaining professional advice (for example, from lawyers).

HOW AND WHEN DO WE SHARE OR DISCLOSE YOUR INFORMATION?

With Our Websites: We may share your information with our websites (www.empoweredfirst.com) for purposes and uses consistent with this Privacy Policy.

To Enhance Our Services: We may share your information with third parties who provide services on our behalf to help with our business activities such as ad technology providers, email service providers, data analyzers, and business intelligence providers for the purpose of enhancing our products and services. These companies are authorized to use your personal information only as necessary to provide these services to Us. These third parties currently may include: Facebook, Google.

Third-Party Marketing: We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but We don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give Us permission. We may request to share your information (including email address) with third-party business partners to provide you with information about and enroll you in clinical trials. In these situations and before sharing your information for these purposes, you will receive a just-in-time notice of the proposed sharing, and We will obtain your consent, or opt in, to such sharing. If you do not opt in, We will not share your information for these purposes.

Third-Party Services: When you interact with a third-party advertiser in our Services, the content creator or advertiser can receive information you share with them, as well as the information needed to complete the transaction, including medical information and contact details.

Asset Sale: We may transfer your Personal Information to a third party in the event of a transfer of all or some of our assets to a third party, provided that the third party agrees to adhere to terms similar to those of this Privacy Policy. Where required by applicable law, We will provide you with an opportunity to reject the transfer of your Personal Information in such cases.

Legal Requirements: We may access, preserve, and share your information in response to a legal request if We have a good faith belief that the law requires Us to do so. We may also access, preserve, and share information when We have a good faith belief it is necessary to detect, prevent, and address fraud and other illegal activity; to protect ourselves, you, and others, including as part of investigations; or to prevent death or imminent bodily harm.

Online Marketing: As described above, We may use, and when appropriate, disclose your Personal Information for marketing and market research purposes to learn more about our users and offer and improve our Services. We will only contact you for direct marketing purposes in accordance with applicable laws. You may opt out of our use of your Personal Information for marketing, market research, or direct marketing purposes at any time as set forth below.

Aggregated Data: We may disclose aggregated, non-personal information about Website users without restriction.

HOW LONG DO WE RETAIN DATA?

We keep your Personal Information for as long as is necessary for the purposes for which it is processed. These periods vary depending on the nature of the information and your interactions with Us.

When the purposes for which We processed your Personal Information have concluded, we will either permanently delete or destroy the relevant Personal Information or anonymize it, in a manner that ensures individuals are no longer identifiable.

YOUR RIGHTS, YOUR CHOICE, YOUR SECURITY

Your Rights

You can make the following choices regarding your Personal Information:

Access to Your Personal Information. You may request access to your personal information that We collect on Our own behalf. If required by law, upon request, We will grant you reasonable access to the Personal Information that We have about you.

Access to Your Personal Information. You may request access to your personal information that We collect on Our own behalf. If required by law, upon request, We will grant you reasonable access to the Personal Information that We have about you.

Changes to Your Personal Information. We rely on you to update and correct your Personal Information. Note that We may keep historical information in Our backup files as permitted by law. If Our Website does not permit you to update or correct certain information, then contact Us at the address described below. If We are processing your information on behalf of one of Our partners, then We will forward your modification request to that partner and/or follow any instructions provided by that partner concerning the modification of information. 

Deletion of Your Personal Information. When We collect information on Our own behalf, We typically retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address described below. If required by law We will grant a request to delete information, but you should note that in some situations We must keep your Personal Information to comply with Our legal obligations, resolve disputes, enforce Our agreements, or for another one of Our business purposes. If We are processing your information on behalf of one of Our partners, then We will forward your deletion request to that partner and await instructions on whether the information should be deleted. 

Objection to Certain Processing.   When We process information on Our own behalf, you may object to Our use of your Personal Information by contacting us at the address described below. 

Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional e-mails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional e-mails, We may still send you service related communications. 

Promotional Mailings. If at any time you do not want to receive offers and/or circulars from Us you can remove yourself from Our mailing lists by e-mailing us (our contact information is below) with "NO SNAIL MAIL" in the subject line along with your name, address and zip code. Please note that Our mailings are prepared in advance of their being sent. Although We will remove your name from Our mailing list after receiving your request, you may still receive mailings from Us that had been initiated prior to your name being removed.

Text Messages and Push Notifications. If you receive a text message from Us that contains promotional information you can opt-out of receiving future text messages by replying “STOP” or “UNSUBSCRIBE.” You control on your device whether you receive push notifications.

Revocation of Consent. If you revoke your consent for the processing of Personal Information, then We may no longer be able to provide you services. In some cases, We may limit or deny your request to revoke consent if the law permits or requires us to do so, or if We are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

To get in touch with Us about any other privacy requests, you may contact us using the online form here.

Your Choice

We also partner with third parties and partners to display advertising on our Websites or to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. Please visit http://preferences-mgr.truste.com/ if you wish to opt out of interest-based advertising. Please visit http://www.youronlinechoices.eu if you are located in the European Union. Please note you may continue to receive generic ads, not based on your Personal Information. You can also choose not to be included in Google Analytics here.

Your Security

The security of your Personal Information is important to Us. We follow generally accepted standards to protect the Personal Information submitted to Us, both during transmission and once it is received, and We take various precautions to protect information against loss and misuse. Nevertheless, transmission of information over the internet is not completely secure, We cannot guarantee the security of your Personal Information, and any transmission is at your own risk.If you have any questions about the security of your Personal Information, you can contact Us here.

Links to third party websites

Our Services may contain links to other websites. This Privacy Policy does not apply to those other websites and We do not accept liability for the content of any other website. Please check the privacy policy of any other website before using and submitting any Personal Information to it.

Changes to this Policy

We may update this Privacy Policy to reflect changes to our information practices. If We make any material changes, then We will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Children's Privacy

We do not knowingly collect, maintain, or use Personal Information from our Website about children under the age of 18. We request that persons under the age of 17 not use our Website without supervision from a responsible adult. We will never request Personal Information from a child under the age of 17 without verifiable parental consent. If We become aware that a child under the age of 17 has sent Personal Information to us without prior parental consent, We will remove his or her Personal Information from our files.

WEBSITE LOCATION, US TRANSFER & PROCESSING

THE SITE IS OPERATED BY EF IN THE UNITED STATES, AND PERSONAL INFORMATION WILL BE PRIMARILY STORED IN THE UNITED STATES. BY PROVIDING PERSONAL INFORMATION TO US, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU ACKNOWLEDGE THAT WE COLLECT, MAINTAIN, PROCESS, AND TRANSFER SUCH INFORMATION IN AND TO THE UNITED STATES AND OTHER COUNTRIES AND TERRITORIES, PURSUANT TO THE LAWS OF THE UNITED STATES OR SUCH OTHER JURISDICTIONS, WHICH MAY PROVIDE LESSER PRIVACY PROTECTIONS THAN EUROPEAN ECONOMIC AREA COUNTRIES, AND TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU ACKNOWLEDGE THAT YOUR INFORMATION MAY THUS BE SUBJECT TO U.S. FEDERAL AND CALIFORNIA STATE LAW AND OTHER FOREIGN LAWS AND ACCESSIBLE TO U.S. AND FOREIGN GOVERNMENTS, COURTS, LAW ENFORCEMENT AND REGULATORY AGENCIES. BECAUSE EF IS LOCATED IN THE UNITED STATES, THESE DATA TRANSFERS TO THE UNITED STATES ARE NECESSARY TO PROVIDE THE SERVICES TO YOU AS SET FORTH IN OUR TERMS OF SERVICE AND TO OPERATE OUR WEBSITE. WHEN APPLICABLE, WE WILL OBTAIN YOUR CONSENT FOR THESE DATA TRANSFERS TO THE UNITED STATES.

EEA/UK Addendum

The following Addendum applies to users who reside in the European Economic Area ("EEA") and the United Kingdom, the provisions of which shall prevail over conflicting provisions in this Privacy Policy for EEA/UK residents only. This addendum does not apply to the Find Care product, which is only available in the United States.

Data Controller

For the purposes of data protection law, the controller is Anhae Limited, can be contacted at hello@anhe.com.

Our Legal Basis for Processing

Our legal basis for processing your personal information will typically be one of the following:

Consent

You have actively consented for us to process data by completing a form on the site, or have indicated your consent with another affirmative act.

Legitimate Interests

Our Legitimate Interests in processing your personal information are:

  • To ensure Our website meets the high standard of usability and security you would expect;
  • To help Us identify areas for improvement;
  • To enable Us to communicate effectively regarding services We offer; and
  • To enable Us to process contacts, queries, or complaints.

Legal Obligation

It is necessary for Us to process your personal information for Us to comply with our legal or regulatory obligations.

Contractual Obligation

It is necessary for Us to process your personal information to perform the tasks associated with a contract to which you are a party, or to take steps at your request prior to you entering into a contract.

Contractual Obligation

It is necessary for Us to process your personal information to perform the tasks associated with a contract to which you are a party, or to take steps at your request prior to you entering into a contract.

Your Data Rights

In addition to your rights of access and correction (rectification) described in “Your Rights” (above), EEA and UK residents have certain other rights defined in the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. We will handle your request in accordance with the law. This means there may be legal reasons why We cannot fulfill all requests.

Consent Withdrawal

You have the right to withdraw your consent in relation to our processing of your personal information based on your consent.You can unsubscribe from our marketing e-mails at any time using our e-mail preferences page, or by clicking on the “unsubscribe” link. If located in the United Kingdom or European Union, you can opt out of EDAA members online advertising networks and behavioral advertising through the European Interactive Digital Advertising Alliance (EDAA)'s consumer opt-out page here.

Erasure

You have the right to ask Us to right to request deletion of your personal information in certain circumstances.

Restriction of Processing

You have the right to request that We restrict the processing of your personal information in certain circumstances.

Object to Processing

You have the right to object to the use or disclosures of your personal information.

Data Portability

You have the right to request We transmit your personal information to you or another company in certain circumstances.We process all requests in accordance with the law, and there may be legal reasons why We cannot fulfill all requests.To exercise these rights, please use Our online form . We have one month to respond to you. You are not required to pay any charge for exercising your rights. For any other questions about this Privacy Policy, please contact Us at HERE if you wish to make a request.

International Transfer

We operate in the United States and transfer, store, and process personal information outside of the EEA/UK. By submitting your personal information, you acknowledge this transfer, storing, and processing.We rely on approved data transfer mechanisms (for example, the EU Standard Contractual Clauses) to ensure that personal information is adequately safeguarded.

Cookies and other Tracking Technologies

With appropriate consent, We use cookies to help Us collect, analyze, improve, secure, and market Our Websites and Services, and to support functionality which enhances your browsing experience.You can read more about how and why We use cookies in our Cookies Policy (below).

Questions & ConcernsIf you have any comments or questions, or are concerned about the way in which We have handled any privacy matter, you can contact Us here

Cookie Policy

Cookies on our services

When you use our Services, you may receive cookies or other similar technologies such as pixel tags from Us and the third parties that collect information on our Services. We use cookies to determine that We give you a high-quality experience on Our Services. We use session cookies that expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) and persistent cookies that remain on your hard drive until you erase them or they expire. How long a persistent cookie remains on your browser depends on how long the visited website has programmed the cookie to last or they can be stored for longer. If you access Our Services from your mobile device, We may collect unique user ID, cell phone model, operating system, and carrier. Gathering your information helps us ensure our website and other services work correctly and support our customer analytic efforts.

We also use cookies to show you advertising that is relevant to your interests. We may share your information with third parties who provide services on our behalf to help with Our business activities such as ad technology providers, email service providers, data analyzers, and business intelligence providers for the purpose of enhancing Our products and services. These companies are authorized to use your information only as necessary to provide these services to us. These third parties include but are not limited to: Facebook, Google.

However, if you prefer, you can change your cookie settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. You may elect to reject cookies by adjusting your settings, but doing so will limit the range of features available to you on our Services and other major websites that use cookies.

There are six types of cookies used on our Services:

1. Essential – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without these cookies, services such as shopping activity and paying activity cannot be provided. These cookies also help keep our Services safe and secure.

2. Information Storage and Access – The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.

3. Personalization – The collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, which inform future selection of advertising and/or content.

4. Ad Selection, Delivery, and Reporting – The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase. This does not include Personalisation, which is the collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as websites or apps, over time.

5. Content Selection, Delivery, and Reporting – The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether the you took any action related to the content, including for example clicking on content. This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, such as websites or apps, over time.

6. Measurement – The collection of information about your use of the content, and combination with previously collected information, used to measure, understand, and report on your usage of the service. This does not include personalisation, the collection of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, i.e. on other services, such as websites or apps, over time.