DR. JEN FABER, LLC (the “Company”) respects the privacy concerns of the users of its website, [www.drjenfaber.com] and the services provided therein (the “Site”). The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information may be used.
We are committed to protecting your privacy and security and have explained in detail the steps we take to do so. We control this site from offices in the United States of America. We do not represent that materials on the site are appropriate or available for use in other locations. Persons who choose to access this site from other locations do so on their own initiative, and are responsible for compliance with local laws, if and to the extent local laws are applicable.
When you submit information to us or visit any of our sites, we use it in an ongoing nature to ensure you receive the information or purchases you’ve made with us, to deliver relevant future content via our email newsletters, to track how much you use our sties or services, and to make future offers through our company or any other company that is involved in delivering your purchases, bonuses or content. By giving us your contact information at any time, you are granting us the right to contact you in the future in any manner necessary at our discretion for ongoing personal and professional development. You can unsubscribe from our email newsletters at any time by clicking the unsubscribe link found at the bottom of all of our emails.
Use of Information:
As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of the Company’s internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.
The Site’s various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give us contact information such as your name, mailing and/or e-mail address, demographic information such as your age and gender, and personal preference information such as your preferred software and interests. Information submitted at the time of submission will be used by the Company only as necessary for our legitimate business interests, including without limitation the improvement of our products, services and the contents of the Site. The Company may also share such information with our business and promotional partners to further those interests. Personally identifiable information is never sold or leased to any third parties. With your permission, we may use your contact information to send you information about our company and products. You may always opt-out of receiving future mailings as provided below. The Company does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.
The Company may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Site, or anyone else that could be harmed by such activities.
As always, you can unsubscribe from any of our emails at any time via the unsubscribe link at the bottom of the email you received from us.
We do not store any information about you on our servers other than that which you submit into one of our forms, and in any case we hold your sensitive information like your credit card information we use software that keeps it encrypted. Any other information stored happens via cookies or pixels as described above, and as facilitated via 3rd party tools (like Facebook, Google or Kajabi). Here is an example of how we may use any information to better communicate with you:
- Provide and administer the Services, including to display customized content and facilitate communication with other users;
- Process your requests and orders for courses, products, specific services, information, or features;
- Communicate with you about your account by:
- Responding to your questions and concerns;
- Sending you administrative messages and information, including messages from instructors and teaching assistants, notifications about changes to our Service, and updates to our agreements;
- Sending you information and in-app messages about your progress in courses, rewards programs, new services, new features, promotions, newsletters, and other available courses (which you can opt out of at any time);
- Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of a mobile app);
- Manage your account preferences;
- Facilitate the Sites’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
- Solicit feedback from users;
- Market and administer surveys and promotions
- Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;
- Identify unique users across devices;
- Tailor advertisements across devices;
- Improve our Sites and develop new products, services, and features;
- Analyze trends and traffic, track purchases, and track usage data;
- Advertise the Services on third-party websites and applications;
- As required or permitted by law; or
- As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.
When you submit information to us, then, we use it in an ongoing nature to ensure you receive the information or purchases you’ve made with us, to deliver relevant future content via our newsletters, and to make future offers through our company or any other company that is involved in delivering your purchases.
As an example, if you purchase certain courses from us, you may receive a bonus coaching session which is delivered from Dr. Jen Faber by a separate system or company that runs that particular program (like one of Dr. Jen’s systems and companies, HouseCallPractice.com). To deliver that coaching, we share your information with House Call Practice’s system so you can access the online program you received as part of your purchase. At any time, you can contact us not to have your information shared with such service providers, but you may lose access to certain purchase bonuses or items if you do not allow the delivering third-party to contact you.
As most of our programs are for ongoing educational purposes in the field of personal and professional development, you should assume we will continue to contact you in perpetuity via email or via social media in order to deliver our services, serve you related content, make recommendations, learn about your preferences, grant you products, deliver programs to you with or from other platforms or companies, advertise to you or look alike audiences, send you surveys, and other fulfillment or marketing purposes.
By using our site(s) and submitting any information with us, you agree to these terms without exception and agree to waive liability and not hold us liable for any use of your information, in perpetuity, under any circumstances, including waiving your right to participate or initiate any class action complaints.
Again, if you want us to no longer contact you, just write us at email@example.com anytime with your request and we will begin removing you from our services or content as appropriate and as soon as we can.
Children Age 13 and Under:
The Company recognizes the special obligation to protect personally identifiable information obtained from children age 13 and under. AS SUCH, IF YOU ARE 13 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 13 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.
The Company nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:
- Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
- Know the sites your kids are visiting and which sites are appropriate.
- Look for Website privacy policies. Know how your child’s information is treated.
- Check out the FTC’s site for more tips on protecting children's privacy online
Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using our Site easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.
Company uses the following cookies on the Site:
|_kjb_session||Kajabi session cookie||Tracks your active admin session so you don't need to re-login|
|kjba||Kajabi affiliate token||Tracks which affiliate has referred an offer purchase|
|_abv||Admin bar hidden||Tracks whether the user wishes their admin previewing bar to be hidden|
When you use our Sites, we or our authorized technology services provider may also collect certain technical and routing information from you to facilitate your use of the Site and its services or to contact you or advertise in the future. We use this information to administer the Site and to understand and measure traffic patterns on the Site so that we know which areas of our sites are favorites of our users, which areas need improvement, and what technologies are being used so that we may continually improve our sites for mobile and future technical platforms. This information is collected mostly in aggregate form, without identifying you or any user individually, however in some cases we use tools like cookies, web beacons, analytics services, and advertising providers 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 our our technology services provider by using “cookies” or “pixels” during your visit. A cookie is 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 many of our pages 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 our Sites or how you interact with our Sites.
If you ever choose to opt-out of targeted advertising with us, then please contact us at firstname.lastname@example.org so that we can remove your email from any advertising we may use.
Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.
Links to External Sites:
Bulletin Boards and Chat Areas:
Guests of the Site are solely responsible for the content of messages they post on the Company’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features. Choice/Opt-Out: The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us at email@example.com, including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.
Third Party Privacy Policies:
We may make available third-party links through hyperlinks or otherwise enable you to access third-party products or services from the Company that are not affiliated with or controlled by us. We are not responsible for those parties, the content of their products or services, or the use of information you provide to them. Providing links or otherwise enabling access to third-party products or services does not constitute sponsorship of or affiliation with those people or companies. You recognize and agree that we are not liable for any third parties use of your personal information and you should review the privacy policies of these third parties.
The Company uses third party vendors and hosting partners to provide the necessary technology required to run the Company. We take all steps reasonably necessary to ensure that your data is treated securely in accordance with this Policy and applicable privacy legislation. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit on or through our website or the Service and you do so at your own risk.
Access to third-party services’ accounts:
These services allow the Company to access personal information from your account on a third-party service and perform actions with it.
Access to Active Campaign
This service allows the Company to send emails through email automation campaigns.
Access to Stripe account (Stripe Inc)
This service allows the Company to connect with the User’s account on the Stripe network, provided by Stripe, Inc.
Access to Kajabi
This service allows the Company to host online products, including but not limited to programs, memberships, and e-books.
Access to LeadPages
This service allows the Company to create opt-in pages hosted on their sites.
Contact Information for Complaints or Concerns: If you have any complaints or concerns about the Company or about this privacy statement, please contact:
Via email: firstname.lastname@example.org
Via regular mail: Dr. Jen Faber, LLC, 75 N Woodward Ave., #89658, Tallahassee, FL 32313.
Information provided by you via general e-mail inquiries to the Company such as your e-mail address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.
Security: Security for all personally identifiable information is extremely important to us. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, The Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to the Company, you accept that you do so at your own risk.
ADDENDUM: GDPR Compliance Standards
Principal Rights. In this Section, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to erase of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims].
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us [see Contact Information for Complaints or Concerns].
Managing cookies. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
"Personal data" is defined in Article 4(1) of the GDPR: "(1) 'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".
How we use your personal data.
Article 13(1) of the GDPR provides that:
"(1) Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information: ... (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing; (d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party".
Article 6(1)(f) of the GDPR provides that:
"(1) Processing shall be lawful only if and to the extent that at least one of the following applies: ... (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child."
Article 14 of the GDPR, which applies where personal information is not obtained from the data subject, provides that information about "the categories of personal data concerned" must be supplied to data subjects.
Article 13 of the GDPR, which applies where personal information is obtained from the data subject, does not include an equivalent provision.
Nonetheless, we have included references to general categories of data in this document, because this facilitates the identification of particular purposes of processing and the legal bases of processing - information which does need to be provided under Article 13.
Article 13(2) of the GDPR provides that, where personal data is collected from a data subject, certain information about data subject rights must be provided:
"In addition to the information referred to in paragraph 1, the controller shall, at the time when personal data are obtained, provide the data subject with the following further information necessary to ensure fair and transparent processing: ... (b) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability; (c) where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal; ...".
Similar provisions are set out in Article 14 in relation to personal data which is not collected from the relevant data subject.
Article 18(1) of the GDPR states:
"The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; (d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
The right to object to processing is detailed in Article 21 of the GDPR, and must be notified to data subjects under Articles 21(4), 13(2)(b) and 14(2)(c).
Article 21(3) of the GDPR states:
"Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes."
The right to data portability is set out in full in Article 20 of the GDPR, and must be notified to data subjects under Articles 13(2)(b) and 14(2)(c).
The right to lodge a complaint with a supervisory authority is set out in Article 77 of the GDPR, and must be notified to data subjects under Articles 13(2)(d), 14(2)(e) and 15(1)(f).
Article 7(3) of the GDPR sets out the right of withdrawal. The right must be notified to data subjects under Articles 13(2)(c) and 14(2)(d). See also Article 17(1)(b).
Last Updated: May 24, 2018.