PRIVACY POLICY

EFFECTIVE DATE: MAY 2018

This Privacy Policy governs the online information collected by Luna Circle on behalf of Debby van Boxtel, d/b/a “debbyixchel.com” (“Company”, “we” or “us”). Specifically, it outlines the types of information that is collected about you while you are using debbyixchel.com (the “Site”, "Sites"), and the ways in which we use this information. This Privacy Policy does not apply to any information you may provide to us or that we may collect offline and/or through other means (for example, at a live event, via telephone, or through the mail). By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy.

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites. We suggest you to check back from time to time to review this Privacy Policy for any changes since your last visit.

Collection and use of information.

We collect various personal information regarding you, including the following:

Information you provide for weekly newsletters, specifically e-mail address, and first name. If you sign up for paid services, we receive a portion of your payment information from our payment processor (such as name, the country of issuance and (e-mail) address) and for tax purposes. We may collect and store personal or other information that you voluntarily supply to us online while using the Site (e.g., while on the Site or in responding via email to a feature provided on the Site). The Site contacts individuals who specifically request that we do so or in the event that they have signed up to receive our free newsletters or have purchased one of our products. The Site collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and e-mail address for registration to receive our free newsletters and name, postal address, and Paypal information when purchasing our products. All of this information is provided to us by you. Your information is stored at the list server that delivers debbyixchel.com newsletters. Your information can only be accessed by those who help manage those lists in order to deliver e-mail to those who would like to receive debbyixchel.com newsletters.

Your marketing preferences. We also collect and store information that is generated automatically as you navigate online through the Site. We also may use a standard feature found in browser software called a “cookie” to enhance your experience with the Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By Showing how and when visitors use the Site, cookies help us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before. The Site also may use web beacons (single-pixel graphic files also known as “transparent GIFs“) to access cookies and to count users who visit the Site or open HTML-formatted email messages.

The Site also includes links to other Sites and provides access to products and Services offered by third parties, whose privacy policies we do not control. When you access another Site or purchase third-party products or Services through the Site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or Services.

The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our Sites is available to others.

Information you share with us in connection with surveys, contests or promotions.

Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.

We may also make some content, products and Services available through our Site through cooperative relationships with third-party providers, where the brands of our provider partner appear on the Site in connection with such content, products and/or Services. We may share with our provider partner any information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our provider partner. In some cases, the provider partner may collect information from you directly, in which cases the privacy policy of our provider partner may apply to the provider partner’s use of your information. The privacy policy of our provider partners may differ from ours. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.

Be aware that we may occasionally release information about our visitors when release is appropriate to comply with law or to protect the rights, property or safety of users of the Site or the public.

We obtain personal information from various sources. We do this in three main ways:

  • You provide some of it directly (such as by registering for the newsletter).  When you use our Services, we collect information from you in a number of ways.  For instance, we ask you to provide your name and email address, your phone number, to register and manage your account. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions. Sometimes we require you to provide us with information for contractual or legal reasons. For example, we may ask you to select your jurisdiction when you sign up for paid Services to determine if, and how much, tax we need to collect from you. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
  • We record some of it automatically when you use our Services (including with technologies like cookies). When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices.  Some of this information is collected automatically using cookies and similar technologies when you use our Services. We let our Users control what cookies and similar technologies are used through their sites (except those we need to use to provide the Services properly, such as for performance or security related reasons). Some of this information is similarly collected automatically through your browser or from your device. When you sign up for our paid Services, we collect your information (such as course materials, video and audio recordings of courses, calls, live events, and materials submitted by Client in the context of the courses and programs, as well as storing these on our membership site) for future lecture, teaching, and marketing materials.
  • We receive some of it from third parties (like when you register for an account using a third party service or when you make payments to us using our payment processor). If you sign up for paid Services, we obtain limited information about your account, such as address, country and name. Currently, our payment processor is Paypal. Paypal uses and processes your complete payment information in accordance with Paypal's privacy policy. Other third parties we use are Dubsado, Google, Facebook, InfusionSoft, ParteQ Finances and WordPress.

We use the personal information we obtain about you to:

Create and manage your account, provide and personalize our Services, process payments and respond to your inquiries.

Provide you with customized Services. For example, we use your location information to display accurate date and time information. We also use cookies and similar technologies for this purpose.

Communicate with you, including by sending you emails about your transactions and service-related announcements.

Administer surveys, contests and other promotions. Promote our Services and send you tailored marketing communications about products, Services, offers, programs and promotions and measure the success of those campaigns. For example, we may send different marketing communications to you based on your preferences or what we think may interest you based on other information we hold about you.

Analyze your interactions with our Services and third parties’ online Services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for paid Services or we may choose to serve you a particular advertisement based on your subscription to our email list or what we think may interest you based on other information we hold about you.

Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and Services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually.

Enforce our Terms & Conditions and other legal terms and policies. Protect our and others’ interests, rights and property.

Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

We process your personal information for the above purposes when:

You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.

We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

We need your personal information to provide you with Services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can read our newsletter or receive coaching services.

We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:

To operate the business and provide you with tailored advertising and communications to develop and promote our business.

To analyze and improve the safety and security of our company - we do this as it is necessary to pursue our legitimate interests in ensuring company is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.

To provide and improve the Services, including any personalized Services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.

To anonymize and subsequently use anonymized information.

To protect your vital interests, or those of others.

We share personal information in the following ways:

Business partners.  We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their third party Services, but only when you have been informed or would otherwise expect such sharing.

Service providers. We share personal information with our Service providers that perform Services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.

Process payments. We transmit your personal information via an encrypted connection to our payment processor.

Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests or prevent fraud or abuse of our clients. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.

Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third party social media platform on which we advertise to avoid serving our ads to people who already use our services.

Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.

In that case, you can access, update, change or delete personal information either directly or by contacting us at info@debbyixchel.com to request the required changes.

You can also elect not to receive marketing communications by changing your preferences in your account or by following the unsubscribe instruction in such communications.

Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.

We maintain security standards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession.

We retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria.

As clients may come back to us after their account becomes inactive, we don’t immediately delete your personal information when your trial expires or you cancel all paid Services. Instead, we keep your personal information for a reasonable period of time, so it will be there for you if you come back.

You may delete your account by contacting us at info@debbyixchel.com and we will delete the personal information we hold about you (unless we need to retain it for the purposes set out in this Privacy Policy).

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.

If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at info@debbyixchel.com.