Politica de Confidențialitate

Data Use Policy

Last updated: December 10, 2024

PRIVACY POLICY / PRIVACY NOTICE

Purpose and who we are

The purpose of this Privacy Notice is to describe how Togetherness Space LLC, our subsidiaries, and our international branches, (the “Company”, “we”, “our”, or “Inspired Life”) collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications), our mobile applications for iOS and Android, and any other website owned or operated by Inspired Life owned and controlled by us, including any content, functionality, and services (the “Services”) offered through any of the foregoing (collectively referred to herein as the “Website”). Please read this Privacy Notice carefully to understand what we do. If you do not understand any aspects of our Privacy Notice, please feel free to contact us at data@togetherness.space . Your use of our Website is also governed by our Terms and Conditions. Terms used but not defined in this Privacy Notice can be found in our Terms and Conditions. Togetherness Space LLC is a company with a principal place of business at 447 Broadway, 2nd FL #770, New York, NY 10013. If you reside or are located in the European Economic Area (“EEA”) Togetherness Space LLC is the data controller of all Personal Data (as defined below) collected via the Website and of certain Personal Data collected from third parties, as set out in this Privacy Notice.

What Information this Privacy Notice Covers

This Privacy Notice covers information we collect from you through our Website. Some of our Website’s functionality can be used without revealing any Personal Data, but for features or Services related to the content and courses made available on our Website to registered participants (the “Content Offerings”), Personal Data is required. In order to access certain features and benefits on our Website, you may need to submit, or we may collect, “Personal Data” (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information”). Personal Data can include information such as your first and last name, date of birth, street address, city, state, zip code, email address, telephone number, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to Inspired Life. Inaccurate information may affect your ability to use the Website, the information you receive when using the Website, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

What You Agree to by Using Our Site

We consider that the legal bases for using your personal information as set out in this Privacy Notice are as follows:

our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms and Conditions of our Website which you accept by browsing our website and/or to comply with our contract to provide Services to you, or other organization that may be providing you with access to our Services); or
our use of your personal information is necessary for complying with our legal obligations; or
use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our Website and provide our Services;
- carry out research and analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by local law.

Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used. We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below). If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you.

What Information We Collect

We gather the following types of information about users through the Website and our Contact Forms: first and last name, date of birth, family status, street address, city, state, zip code, email address, telephone number, IP address, and device identifier.

Information relating to your use of our Website. When users come to our Website, we may track, collect, and aggregate information indicating, among other things, which pages of our Website were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our Website. Collecting such information may involve logging the IP address, operating system, and browser software used by each user of the Website. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of their point of connectivity. We may also use cookies and web beacons when you visit our Website. For more information on our use of cookies and web beacons, please refer to our Cookies Policy.
Personal Data provided directly by you or via third parties. We collect Personal Data that you provide to us when you register for a Masterclass (a “Masterclass” is an online event on a parenting topic, held by an Inspired Life certified trainer, live or recorded), purchase products, complete a survey, sign-up for email updates, and/or send us messages. We may use the Personal Data that you provide to respond to your questions, send you updates about our Events (the “Events” are the free online or offline Masterclasses, live or recorded, held by an Inspired Life certified trainer), and send you email messages.
- Updates. Inspired Life may offer you the ability to receive updates via email. In order to subscribe to this Service, you may be required to provide us with Personal Data such as your name and email address.
- Participation in our Events. Inspired Life offers users the opportunity to participate in Live Events (the “Live Events” are live online or offline Masterclasses or workshops held by our certified trainers) on or through the Website. If you desire to participate in a Live Event, you will be asked to complete a quiz and provide us with certain information necessary to register to one or more Events. This information may include, among other things, your full name and email address.
- Communications with Inspired Life. We may receive Personal Data when you send us a message or otherwise contact us.
- By participating in our services and providing your personal data, you consent to Inspired Life using your data to invite you to join our various community groups and channels on platforms such as Facebook, WhatsApp, Telegram, and other similar platforms. This includes, but is not limited to, sending invitations to join these groups, adding you to relevant groups or channels, and managing your participation within these communities. We use your data for the following purposes:

* Inviting you to join our community groups and channels on various platforms. * Managing and administering these groups and channels, including sending you relevant updates, notifications, and communications. * Facilitating discussions, providing support, and enhancing your experience within our community. Your participation in these groups and channels is voluntary, and you can opt-out at any time by contacting us or using the platform’s built-in opt-out mechanisms.

Third Party Sites. We may receive Personal Data when you access or log-in to a third party site, e.g., Facebook, from our Website. This may include the text and/or images of your Personal Data available from the third party site.
Third Party Payment Processing. Inspired Life provides you with the ability to pay for our Program using a credit card or other methods through a third party payment processing service provider. Please note that Inspired Life collects and processes your financial information.

In the course of delivering our products and services, we will record audio and video of participants (clients/customers). By participating in our services, You consent to the recording, storage, and use of your voice and image for: (1) provision of our services, (2) marketing purposes, and (3) creation and commercial exploitation of content and programs. This includes our right to produce, sell, distribute, and monetize any programs, content, or derivative works created using these recordings, in whole or in part, through any medium and in any territory worldwide. These recordings may be used for quality assurance, training, and promotional purposes.

Additional information regarding how we use your personal data can be found in the next section of this policy.

How We Use the Information

Information relating to your use of our Website. We use information relating to your use of the Website to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Website. We may also use this information to ensure the security of our Services and the Website.
Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Policy or as specifically agreed to by you, Inspired Life will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personal Data as described below.
- Providing the Website and our Services. We use Personal Data which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or Services that you request from us.
- Technical support and security. We may use Personal Data to provide technical support to you, where required, and to ensure the security of our Services and the Website.
- Updates. We use Personal Data collected when you sign-up for one of our Events to send you the messages in connection with the Event you registered for or upcoming Events. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Participation in Live Events. We use the Personal Data that we collect from you when you participate in a Live Event through the Website for processing purposes, including but not limited to tracking attendance, progress, and completion. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Communications with or from Inspired Life. When you send us a message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.

External Links

For your convenience we may provide links to sites operated by organizations other than Inspired Life (“Third Party Sites”) that we believe may be of interest to you. We do not disclose your Personal Data to these Third Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personal Data.

Retention of Personally Identifiable Information

The maximum length of time we will retain certain categories of data is up to five (5) years for fiscal auditing purposes, or for the amount of time you are actively benefiting from the educational products or services offered by Togetherness Space LLC and its subsidiaries, that cannot be delivered without said personal data. At any point during this time you can make use of your right to be forgotten with an email request to data@togetherness.space, according to local applicable data privacy regulations.

Confidentiality & Security of Personally Identifiable Information

We will use industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that email communications are typically not encrypted and should not be considered secure.

Updating or Deleting Your Personal Data

You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material or updates from us, and request that we delete or provide you with a copy of your personal data. If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via data@togetherness.space or by writing to us at the following address: 447 Broadway, 2nd FL #770, New York, NY 10013. You have the right to request that we:

provide access to any Personal Data we hold about you;
prevent the processing of your Personal Data for direct-marketing purposes;
update any Personal Data which is out of date or incorrect;
delete any Personal Data which we are holding about you;
restrict the way that we process your Personal Data;
provide your Personal Data to a third party provider of services; or
provide you with a copy of any Personal Data which we hold about you.

We try to answer every request promptly, where possible, and provide our response within the time period stated by applicable law. You also have the right to lodge a complaint with the National Data Protection Authority. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.

CALIFORNIA CONSUMER PRIVACY ACT NOTICE (CCPA)

This notice addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (“CCPA”). It is incorporated into the Inspired Life Privacy Policy and applies to personal information about California residents using our Website and Services (“Consumers,” “You,” or “Your”) that we collected over the previous 12 months. For purposes of the CCPA, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. In the event of a conflict between this CCPA Notice and any of our other privacy policies, this CCPA Notice shall control only with respect to the personal information of California residents. For more information about the data we collect and how we use it, please review our Privacy Policy.

Personal Information Purposes of Processing

This section describes the purposes for which we collect and use personal information. We collect and use personal information regarding California residents for the purposes described below:

run, grow and develop our business;
operate our Website and provide our Services;
carry out research and statistical analysis;
carry out marketing and business development; and
for internal administrative and auditing purposes.â

We do not sell your personal information and we do not have actual knowledge that we sell the personal information of minors under 16 years of age. We may disclose personal information to other parties as follows:

Service Providers

We may disclose personal information to our service providers in order to have them perform services that assist us in fulfilling the purposes listed above. Our service providers provide us with a range of services including: hosting our Site, processing payments, legal and accounting professional services, postal and email delivery, conducting analysis to improve our products and Website, fulfilling requests you make, managing payments, and answering your questions. We don’t allow our service providers to retain, use, or otherwise handle the data we provide to them for their own purposes.

Security

We may disclose personal information to our partners, service providers, and law enforcement to secure our Website and Services, including to detect, prevent, and investigate security incidents or violations of our Terms of Use or applicable laws.

Audits

We may disclose personal information to our partners and service providers in order to audit interactions and transactions for legal compliance and other purposes.

Service Improvements

We may disclose personal information to our service providers in order to improve our Website and Services, such as to identify bugs, repair errors, or ensure that services function as intended, or conduct internal research and analysis to improve our technology. We may disclose personal information to third parties at your direction.

Personal Information Categories

Our Privacy Policy covers our personal information collection and usage more fully. The chart below describes the categories of personal information we collect and the sources from which we collect the personal information, organized into the categories specified by the CCPA.

Personal Information Category	Sources
Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, state identification card number, credit card or debit card number, and other financial information)	Information you provide directly or through your interactions with our Services Information.
Identifiers (e.g., real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)	Information you provide to us directly or through your interactions with our Website and Services (as defined in our Terms of Use and Privacy Policy) Vendors that provide information to help us serve relevant ads and understand the ads’ effectiveness.
Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”)	Information you provide to us directly.
Commercial information (e.g., information regarding products or services purchased, obtained, or considered)	Information you provide to us directly, such as purchasing a full program or subscription. Your interactions with our Website and Services Information from our partners.
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services)	Your interactions with our Website and Services.
Geolocation Data	Information you provide to us directly or through your interactions with our Website and Products.
Inferences	Information you provide to us directly or through your interactions with our Website.
Audio, electronic, visual or similar information	Information you provide directly or through your interactions with our Website.

We use this personal information for the purposes outlined in our Privacy Policy.

California Residents’ Privacy Rights

California residents have rights to request access to or deletion of their personal information and may not be discriminated against because they exercise any of their rights under the California Consumer Privacy Act in violation of Cal. Civ. Code §1798.125. You can make requests as follows: (1) send an email to data@togetherness.space or (2) writing to us at 447 Broadway, 2nd FL #770, New York, NY 10013 with details of your specific request. We may ask that you provide certain information to verify your identity, and the information we request from you will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why. You may designate an authorized agent to make a request under the CCPA on your behalf if: (1) the authorized agent is a natural person or a business entity registered with the Secretary of State of California; and (2) you sign a written declaration that you authorize the authorized agent to act on your behalf. We may ask that you provide certain information to verify your identity and that you authorized the authorized agent to act on your behalf. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA. California residents also have the right to opt out of the sale of their personal information; Inspired Life does not provide this option as we do not sell your personal information. If you have any questions or concerns regarding this CCPA Notice, please email data@togetherness.space .

VIRGINIA CONSUMER DATA PROTECTION ACT (VCDPA) NOTICE

Inspired Life is dedicated to safeguarding the privacy and personal data of all our customers. This notice outlines how we collect, use, protect, and disclose personal data in accordance with the Virginia Consumer Data Protection Act (VCDPA). The Virginia Consumer Data Protection Act (VCDPA) applies to any person who conducts business in the state of Virginia or provides services or products to Virginia residents.

Collection of Personal Data

We may collect personal data, including but not limited to full name, date of birth, email address, phone number, street address, city, state, zip code, email address, telephone number, IP address, and device identifier when you register for our live masterclasses or purchase our parenting program. Personal data is collected through various channels, including our Website, mobile application, and communication channels, as well as through offline interactions. We may also collect personal data indirectly from third-party sources, provided they have obtained the necessary consent to share the data.

Use of Personal Data

We use the collected personal data for the following purposes:

Providing access to our masterclasses, parenting program, and associated Services.
Personalizing and improving our Services, content, and communications to enhance the user experience.
Processing payments, managing subscriptions, and fulfilling orders.
Communicating with you regarding our Services, updates, offers, and promotions, subject to your consent where applicable.
Responding to your inquiries, providing customer support, and resolving any issues.
Conducting research, data analysis, and internal reporting to enhance and optimize our services.

Legal Basis for Processing

Our processing of personal data is based on one or more legal grounds, including:

Your explicit consent, which you provide when registering for our Services or subscribing to our communications.
The necessity of processing for the performance of a contract between you and Inspired Life.
Compliance with legal obligations, such as financial and accounting requirements.
Legitimate interests pursued by Inspired Life, such as improving our services and marketing our offerings, subject to your rights and interests.

Data Sharing and Disclosures

We may share personal data with trusted third-party service providers who assist us in delivering our services, such as payment processors, customer support platforms, and hosting providers. These service providers are contractually obligated to handle your data securely and only for the specified purposes. We may share personal data with law enforcement authorities, government agencies, or other third parties when required to comply with applicable laws, regulations, legal processes, or enforceable governmental requests. In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring party, subject to applicable privacy laws.

Data Security

We implement and maintain reasonable security measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. Our security measures include administrative, technical, and physical safeguards, regular vulnerability assessments, and encryption of sensitive data during transmission.

Data Retention

We retain personal data for as long as necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. Personal data that is no longer required will be securely deleted or anonymized.

Individual Rights

You have certain rights regarding your personal data, including:

The right to access and obtain a copy of your personal data that we hold.
The right to correct inaccurate or incomplete personal data.
The right to request the deletion of your personal data, subject to legal obligations and legitimate interests.
The right to restrict the processing of your personal data in certain circumstances.
The right to data portability, allowing you to receive your personal data in a structured, commonly used, and machine-readable format.
The right to withdraw your consent for processing personal data, where applicable.
The right to lodge a complaint with the relevant data protection authority if you believe your rights have been violated.

Cookies and Tracking Technologies

Our website may use cookies, web beacons, and similar tracking technologies to enhance user experience, personalize content, analyze website traffic, and track user interactions. You can manage your cookie preferences through your browser settings and opt-out of certain types of tracking technologies.

Cross-Border Data Transfers

As a global organization, we may transfer personal data to recipients in countries outside of Virginia or your home country. We ensure that such transfers comply with applicable data protection laws and take appropriate safeguards to protect your personal data.

Updates to this Notice

We may update this VCDPA notice to reflect changes in our data practices or legal requirements. We highly encourage you to periodically review this notice for any updates. If you have any questions or concerns regarding this VCDPA Notice, please email us at data@togetherness.space .