Protecting your private information is our priority. This Statement of Privacy applies to Xtreme Education and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Xtreme Education include all affiliations. The Xtreme Education website is a Training and Educational site. By using the Xtreme Education website, you consent to the data practices described in this statement. 
 
Collection of your Personal Information 
In order to better provide you with products and services offered on our Site, Xtreme Education may collect personally identifiable information, such as your: 
 
-    First and Last Name 
-    Mailing Address 
-    E-mail Address 
-    Phone Number 
-    Employer 
-    Job Title 
-    Licenses and Certifications 
 
If you purchase Xtreme Education's products and services, we collect billing and credit card information. This information is used to complete the purchase transaction. 
 
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Xtreme Education's public message boards, this information may be collected and used by others. 
 
We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services available on the Site. These may include: (a) registering for an account on our Site; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit card or other payment information when ordering and purchasing products and services on our Site. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future. 
 
Use of your Personal Information 
Xtreme Education collects and uses your personal information to operate its website(s) and deliver the services you have requested. 
 
Xtreme Education may also use your personally identifiable information to inform you of other products or services available from Xtreme Education and its affiliates. 
 
Sharing Information with Third Parties 
Xtreme Education does not sell, rent or lease its customer lists to third parties. 
 
Xtreme Education may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Xtreme Education, and they are required to maintain the confidentiality of your information. 
 
Xtreme Education may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Xtreme Education or the site; (b) protect and defend the rights or property of Xtreme Education; and/or (c) act under exigent circumstances to protect the personal safety of users of Xtreme Education, or the public. 
 
Tracking User Behavior 
Xtreme Education may keep track of the websites and pages our users visit within Xtreme Education, in order to determine what Xtreme Education services are the most popular. This data is used to deliver customized content and advertising within Xtreme Education to customers whose behavior indicates that they are interested in a particular subject area. 
 
Automatically Collected Information 
Information about your computer hardware and software may be automatically collected by Xtreme Education. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Xtreme Education website. 
 
Links 
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. 
 
Security of your Personal Information 
Xtreme Education secures your personal information from unauthorized access, use, or disclosure. Xtreme Education uses the following methods for this purpose: 
 
-    SSL Protocol 
 
When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol. 
 
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed. 
 
Children Under Thirteen 
Xtreme Education does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website. 
 
Disconnecting your Xtreme Education Account from Third Party Websites 
You will be able to connect your Xtreme Education account to third party accounts. BY CONNECTING YOUR XTREME EDUCATION ACCOUNT TO YOUR THIRD-PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO OTHERS (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD-PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONALLY IDENTIFYING INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE THIS FEATURE. You may disconnect your account from a third-party account at any time. To see what you've given permission to access your data, check out your App Settings page. You might be shocked just how many are listed, and although some will be familiar, there's a good chance many won't be.

Click any of the apps here to see what information you're sharing with its developers. You can choose to stop sharing certain types of information with an app, though you can't stop it accessing your public profile without disconnecting it completely. If you want to stop sharing your Facebook data with any third parties, select 'Edit' under 'Apps, websites and plug-ins' and disconnect your account from the Facebook Platform (a set of tools and services for developers to create their own products). 
 
E-mail Communications 
From time to time, Xtreme Education may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from Xtreme Education or click on a link therein. 
 
If you would like to stop receiving marketing or promotional communications via email from Xtreme Education, you may opt out of such communications by Customers may unsubscribe from emails by "replying STOP" or "clicking on the UNSUBSCRIBE button.". 
 
External Data Storage Sites 
We may store your data on servers provided by third party hosting vendors with whom we have contracted. 
 
Changes to this Statement 
Xtreme Education reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and/or by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy. 

 

Who We Are
At Xtreme Education, we are committed to maintaining the trust and confidence of all visitors to our web site. In particular, we want you to know that Xtreme Education is not in the business of selling, renting or trading email lists with other companies and businesses for marketing purposes.

In this Privacy Policy, we’ve provided detailed information on when and why we collect personal information, how we use it, the limited conditions under which we may disclose it to others, and how we keep it secure.

We take your privacy seriously and take measures to provide all visitors and users of Xtreme Education with a safe and secure environment.

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Cookies
Xtreme Education may set and access Xtreme Education cookies on your computer.  Cookies are used to provide our system with the basic information to provide the services you are requesting.  Cookies can be cleared at any time from your internet browser settings.

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Google Analytics
When someone Xtreme Education  we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to track things such as the number of visitors to the various parts of the site and interactions with the site. This information is processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of visitors to our website.

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Website Comments
When someone visits Xtreme Education, there may be an ability to submit comments on particular articles or pages.  When comments are submitted, you are entitled to use aliases or information that completely hides your identity. When a comment is submitted, the relevant details (name, email, website) that you provide are stored.  These details are stored so that we can display your comment back to you, and to anyone viewing the comment sections on the site. We do not verify information entered nor do we require verification.

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Third Parties
There may be some circumstances where your IP address, geographic location, and other browser related details may be shared with third party companies.  We may share your above mentioned data with following third party companies from time to time.

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Access to Your Personal Information
You are entitled to view, amend, or delete the personal information that we hold. Email your request to our data protection officer Tara at training@xtremeeducation.com and we will work with you to remove any of your personal data we may have.

 

Changes to Our Privacy Policy
We may make changes to our Privacy Policy in the future, however, the most current version of the policy will govern our processing of your personal data and will always be available to you.

If we make a change to this policy that, in our sole discretion, is material, we will notify you by an update or email, where possible. By continuing to access or use our services, you agree to be bound to the terms of our Privacy Policy.

 Affiliate Disclosure

 Disclosure: We are a professional review site that receives compensation from the companies whose products we review. We test each product thoroughly and give high marks to only the very best. We are independently owned and the opinions expressed here are our own.

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Amazon Affiliate Disclosure Policy 
Xtreme Education LLC is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to www.xtreme-education.myshopify.com.

Contact Information 
Xtreme Education welcomes your questions or comments regarding this Statement of Privacy. If you believe that Xtreme Education has not adhered to this Statement, please contact us at: 
 
Xtreme Education
PO Box 671

West, TX 76691
 
Email Address: 
training@xtremeeducation.com
 
Telephone number: 
+1888-849-8736

 

 
Effective as of 11/1/2023

 

 

Xtreme Education General Data Protection

Regulation & Privacy Policy

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Xtreme Education is part of the group which includes 1 Xtreme Education, Xtreme Event Staffing Solutions, Xtreme Education online learning systems, and Xtreme Education's Shopify online store. This privacy policy will explain how our organization uses the personal data we collect from you when you use our website.

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Topics:

• What data do we collect?

• How do we collect your data?

• How will we use your data?

• How do we store your data?

• Marketing

• What are your data protection rights?

• What are cookies?

• How do we use cookies?

• What types of cookies do we use?

• How to manage your cookies

• Privacy policies of other websites

• Changes to our privacy policy

• How to contact us

• How to contact the appropriate authorities

 

What data do we collect?

 

Our Company collects the following data:

• Personal identification information required to maintain required student records and rosters (Name, email address, phone number, etc.)

• Any payment information used to purchase any items or services offered by Xtreme Education

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How do we collect your data?

 

You directly provide Xtreme Education with most of the data we collect. We collect data and process data when you:

• Register online or place an order for any of our products or services.

• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.

• Use or view our website via your browser's cookies.

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Xtreme Education may also receive your data indirectly from the following sources:

• Our Shopify online store

• Our online learning system(s)

 

How will we use your data?

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Xtreme Education collects your data so that we can:

• Process your order, manage your account.

• Email you with special offers on other products and services we think you might like.

• Maintain education records

If you agree, Xtreme Education will share your data with our partner companies so that they may offer you their products and services.

• Shopify

• Thinkific, or any other online learning system utilized by Xtreme Education

• Wix

• Pearson

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When Xtreme Education processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.

How do we store your data?

 

Xtreme Education securely stores your data in secure cloud-based storage, as well as at their location of business at 411 Meadow Dr, West, TX 76691

Xtreme Education will keep your personal information for a period of no less than 7 years. Once this time period has expired, we will delete your digital content data, as well as any paper copies of any personal information.

Marketing

 

Our Company would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.

 

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop Xtreme Education from contacting you for marketing purposes or giving your data to other members of Xtreme Education.

If you no longer wish to be contacted for marketing purposes, please follow the instructions within your email of how to "unsubscribe."

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What are your data protection rights?

 

Xtreme Education would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

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The right to access - You have the right to request Xtreme Education for copies of your personal data. We may charge you a small fee for this service.

The right to rectification - You have the right to request that Xtreme Education correct any information you believe is inaccurate. You also have the right to request Xtreme Education to complete information you believe is incomplete.

 The right to erasure - You have the right to request that Xtreme Education erase your personal data, under certain conditions.

The right to restrict processing - You have the right to request that Xtreme Education restrict the processing of your personal data, under certain conditions.

The right to object to processing - You have the right to object to Xtreme Education's processing of your personal data, under certain conditions.

The right to data portability - You have the right to request that Xtreme Education transfer the data that we have collected to another organization, or directly to you, under certain conditions.

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If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: training@xtremeeducation.com Call us at: 888-849-8736

Or write to us: Xtreme Education, 717 FM 645, Tennessee Colony, TX 75861

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What are cookies?

 

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

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How do we use cookies?

 

Xtreme Education uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in

• Understanding how you use our website

• To improve the products and services that are offered by Xtreme Education

 

What types of cookies do we use?

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There are a number of different types of cookies, however, our website uses:

• Functionality - Xtreme Education uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

• Advertising - Xtreme Education uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Xtreme Education sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you

visit another website, you may be shown advertising based on your browsing patterns on our website.

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How to manage cookies

 

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

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Privacy policies of other websites

 

The Xtreme Education website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

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Changes to our privacy policy

 

Xtreme Education keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 21 November 2019.

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How to contact us

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If you have any questions about Xtreme Education's privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: training@xtremeeducation.com

Call us: 888-849-8736

Or write to us at:  Xtreme Education, PO Box 671, West TX 76691

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How to contact the appropriate authority

 

Should you wish to report a complaint or if you feel that Xtreme Education has not addressed your concern in a satisfactory manner, you may contact the following organizations:

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Cybersecurity Unit at 1301 New York Avenue, N.W., 6th Floor, Washington, D.C. 20530 - CYBERSECURITY.CCIPS@USDOJ.GOV - (202)514-1026

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Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113, Fax: 01625 524510

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National Cyber Security Centre at https://report.ncsc.gov.uk/

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LGPD Compliance

What Is the LGPD?

The LGPD, or Lei Geral de Protecao de Dados, is Brazil’s version of the EU’s General Data Protection Regulation (GDPR). It goes into effect on August 15, 2020. Similar to the GDPR, the LGPD requires companies to comply with requirements related to the processing of personal data. By providing protection to personal data, Brazil is anticipating an increase in business investments, especially in the digital economy. The safety provided to consumers and businesses alike benefit everyone under LGPD.

The LGPD defines data processing principles, outlines what personal data is covered, and develops the ANPD, a new entity responsible for overseeing and enforcing data protection laws across Brazil.

Who Does the LGPD Apply To?

The LGPD applies to any individual, business or organization that gathers the personal data of anyone in Brazil. Specifically, the LGPD regulates data controllers and processors of personal data. Even companies that aren’t located in Brazil may need to comply if they have customers or clients in Brazil.

The information covered by the LGPD includes the collection, processing, use, and storage of all personal data in both electronic and physical form. There is no size specification for companies that must comply with the LGPD. Any business who handles even small-scale processing must comply if they gather personal data or provide goods to anyone in Brazil.

What is Personal Data Under the LGPD?

Personal data in the LGPD is similar to the definition of personal data outlined in the GDPR. The LGPD doesn’t outline a specific definition for personal data like the GDPR and CCPA do, but there are some clarifying factors that the regulation mentions.

Personal data is loosely defined as information that can identify a person, also known as a data subject. It can also apply to personal information that could subject an individual to “a specific treatment.” It applies to data processed in Brazil, data collected in Brazil, or is related to the supplying of goods and services to individuals in Brazil.

Anonymized data is not considered personal data unless it can easily be reversed to get the identifiable data.

What is the ANPD?

The Autoridade Nacional de Proteção de Dados (ANPD) is a new federal entity responsible for issuing guidelines and enforcing data protection laws in Brazil. While the entity operates under the president, it is still considered an organization with decision-making powers. It can also be referred to as the National Data Protection Authority.

It consists of two segments in the organization, the Board of Directors and the National Council. Altogether, the ANPD will have 28 members who play the role of an advisory board.

The ANPD will be responsible for—

• Provide guidelines for the implementation of the LGPD.

• Oversee complaints from consumers/data subjects.

• Investigate and audit specific sanctions to the law.

• Work cross-functionally with data protection organizations in other countries.

• The interpretation of the LGPD.

Any breaches must also be reported to the ANPD. They can then verify the seriousness of a breach and order the data controller to adopt measures to mitigate the effects and disclose the event.

Ten Legal Bases for Processing Personal Data

The LGPD lists ten legal bases for companies to lawfully process personal data in Article 7. The processing must be for “legitimate, specific and explicit purposes of which the data subject is informed.”

The ten legal bases outlined in the LGPD are:

1. With consent from the data subject

2. To comply with a legal or regulatory obligation of the controller

3. To execute public policies provided in laws or regulations, or based on contracts, agreements, or similar instruments

4. To execute a contract or preliminary procedures related to a contract of which the data subject is a party, at the request of the data subject

5. For carrying out studies by research entities, ensuring, whenever possible, the anonymization of personal data

6. For the regular exercise of rights in judicial, administrative or arbitration procedures, the last pursuant to the Brazilian Arbitration Law.

7. For the protection of life or physical safety of the data subject or a third party

8. To protect health, in a procedure carried out by health professionals or by health entities

9. When necessary to fulfill the legitimate interests of the controller or a third party

10. For the protection of credit

Compliance with LGPD

The LGPD is the biggest international data privacy regulation since GDPR. Brazil has nearly 140 million internet users, making it the largest market in Latin America. Because of this, many companies will be impacted by the enacting of the regulation in August 2020.

Complying with the LGPD is similar in many ways to the GDPR. Companies must obtain consent from a data subject before the company can gather their personal data on their website, and the consent must be freely given by the consumer before any gathering of personal data can take place.

Steps to LGPD Compliance:

1. Inform data subjects on how their personal data will be processed in a clear, easy to understand way prior to the point of collection.

2. Obtain consent from the data subject prior to the point of collection. The consent must be freely given and not implied, similar to the GDPR.

3. Have a comprehensive privacy policy that explains how and why the data is being collected.

4. Notify the data subjects and local authorities in the event of a data breach.

5. Appoint a Data Protection Officer (DPO) who is responsible for receiving complaints and communications.

6. Adopt technical and administrative security measures to protect personal data from unauthorized access, accidents, loss, destruction and more.

7. Fulfill data subject requests in a reasonable time. There is not a specific deadline for when a company must provide the information that the data subject requests, only within a reasonable amount of time.

How CookiePro Helps with Cookie Compliance for LGPD

The LGPD also applies to cookies and maintaining cookie compliance is important. Because cookies contain identifiable information, they are subject to regulation by the LGPD. CookiePro offers solutions to aid in compliance with GDPR, CCPA, and LGPD. Here’s just a few ways CookiePro can help with LGPD cookie compliance.

Consent and the right to opt-out

• Collect consent through any medium, including online web forms and mobile apps.

• CookiePro has resources that allow you to track consent and give data subjects the right to opt out of the processing of their personal data.

• Build a preference center customized to your brand and purpose to give data subjects complete control over their right to opt out.

Right of Information

• Handle the process of the data subject’s request in a timely and legally compliant manner.

• Create customized data subject request forms, verify identity, configure deadlines, assign tasks, use multilingual response templates, and communicate securely with data subjects in an encrypted, fully secure messaging portal.

• Maintain records of all data subject requests and interactions to demonstrate compliance

• Use roles-based access controls to develop region-specific workflows specific to LGPD.

Right of Access

• Capture consumer requests through customized intake forms on your website with CookiePro’s Data Subject Rights tool.

• Pinpoint where an individual’s personal data resides and how it’s used with detailed data lifecycle information.

• Locate the data by searching through your data inventory.

Rights for Data Subjects

Under the LGPD, consumers in Brazil have new rights in understanding and consenting to the processing of their personal data. Article 18 is where the nine fundamental rights that data subjects have under LGPD are outlined. GDPR provides very similar rights to EU residents as well.

Data subjects in Brazil will have the right to—

• Receive confirmation of the existence of the processing from the company gathering the data

• Access the data collected on them

• Correct incomplete, incorrect, or outdated data

• Anonymize or delete unnecessary data that does not comply with the LGPD

• Make an express request for the portability of data to another company or “product provider”

• Request the deletion of personal data processed, even if it was done with consent

• Information about public and private companies with whom the controller has shared personal data

• Revoke consent

• Information about the ability to deny consent and the consequences of the denial of consent

Here’s a broad overview of some of the most important rights afforded to data subjects in Brazil under LGPD.

Consent and Opt Out

The LGPD requires that consent is freely given, informed, and unambiguous. Data subjects can control how their personal data is collected and used. Data subjects must be informed about the processing of their data in a clear, adequate, easily accessible and transparent way. Consent must be provided by the data holder in writing or by other means that demonstrates their consent. The consent must be specific to the purposes and can be withdrawn by the data subject at any time.

Request the Data That A Company Holds on Them

If a data subject submits a request, the controller must respond with the confirmation of the existence of data processing operations.

The data controller must provide a clear and complete declaration that includes the—

• Origin of the data

• Purpose of the processing

• Controller contact information

• If the information is shared with other entities

• Rights of the data subject with explicit reference to Article 8 of the LGPD.

Access the Data Held on Them

The personal data must be stored in a format and provided to the data subject only on receipt of a “verifiable consumer request.” The data subject can determine whether the data will be provided electronically or physically in paper form.

Penalties

The penalties for not complying with LGPD are slightly less harsh than the 4% gross revenue penalty in the GDPR. Noncompliance with the LGPD may result in fines of up to 2 percent of the organization’s economic gross revenue in Brazil or fifty million Brazilian Reais per violation.

The fines are applied separately for each violation, which poses significant consequences for data processors and data controllers in the event of noncompliance.

Remaining compliant is not only a best practice for handling the personal data you collect on individuals, it’s also a way to avoid these kinds of hefty fines.

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California Consumer Privacy Act (CCPA)

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Introduction

We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit this website and our practices for collecting, using, maintaining, protecting, and disclosing that information.

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This policy applies to information we collect:

• On this Website.

• In email, text, and other electronic messages between you and this Website.

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy. It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by us; or

• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.

Information We Collect About You and How We Collect It

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We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number or any other identifier by which you may be contacted online or offline (”personal information”);

• That is about you but individually does not identify you; and/or

• About your internet connection, the equipment you use to access our Website, and usage details. We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.

• From third parties, for example, our business partners.

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Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our service, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes. Information We Collect Through Automatic Data Collection Technologies As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. • Information about your computer and internet connection, including your IP address, operating system, and browser type.

  The information we collect automatically is only statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: • Estimate our audience size and usage patterns. • Store information about your preferences, allowing us to customize our Website according to your individual interests. • Recognize you when you return to our Website. The technologies we use for this automatic data collection may include: • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To notify you about changes to our Website or any products or services we offer or provide though it.

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.

• We may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website. California residents may have additional personal information rights and choices. Please see [Your California Privacy Rights] for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/privacy-laws.

Notice to European Users

This Site and the services on this Site are targeted for users in the United States of America. Any information you enter on this Site may be transferred outside of the European Union to the United States of America which does not offer an equivalent level of protection to that required in the European Union. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union’s Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of personal data from the European Union to a third country if the individual has unambiguously given his consent to the transfer of personal information, regardless of the third country’s level of protection. By using this Site or the services, you consent to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in the European Union and to the processing of that information by the Company on its servers located in the United States of America as described in this Privacy Policy.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: marketing@nva.com.

Privacy Notice for California Residents

Effective Date: March 2019

Last Reviewed on: March 2019

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category A: Identifiers

Examples: A real name, Internet Protocol address, email address, or other similar identifiers.

Collected: YES

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: NO

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: NO

Personal information does not include:

• Publicly available information from government records.

• De-identified or aggregated consumer information.

• Information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete on our website.

• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

• We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose [or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights)]. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. [The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.]

We share your personal information with the following categories of third parties: Vetstoria, our online booking tool. Please see https://www.vetstoria.com/privacy-policy/for their privacy policy.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.

Sales of Personal Information

In the preceding twelve (12) months, Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and

• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

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To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to [45/90] days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and uses your information described below [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows

• Via our website: please send us an electronic message through our website

• Write us at our address listed on our webpage.

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