Privacy Notice

Introduction

This privacy notice (“Privacy Notice”) provides information about how Customized Interactions, LLC, collects, uses, and transfers information about you through this website (the “Website”). Carefully review this Privacy Notice, as your use of the Website is subject to this Privacy Notice and the Website Terms of Use.

By submitting your information to us, you agree to the processing set out in this Privacy Notice. Further notices highlighting certain uses we wish to make of your personal data together with the ability to opt in or out of selected uses may also be provided to you when we collect personal data from you.

This Website may contain links to other third-party websites. If you follow a link to any third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.

Information we may collect about you

We may collect and process the following information about you:

1.    Information you actively submit.  We collect any data you provide directly, including:

Category of Personal Data

Description

Legal Basis for Processing

Account Data

In order to use certain features (like accessing content), you need to create a user account, which requires us to collect and store your name, email address, password, and account settings. 

·      Performance of contract

·      Legitimate interests (service provisioning, identity verification, communication, fraud prevention and security)

Learning Data

When you access content, we collect certain data including which courses you’ve started and completed, content and subscription purchases, and your comments posted to the Website.

·      Performance of contract

·      Legitimate interests (service provisioning, platform functionality)

Payment Data

If you make purchases, we collect certain data about your purchase (such as your name, billing address, and ZIP code) as necessary to process your order. You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. For security, Customized Interactions does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

·      Performance of contract

·      Legal obligation

·      Legitimate interests (payment facilitation, fraud prevention and security, compliance)

Communications and Support

If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, messages, location, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Notice.

·      Legitimate interests (customer and technical support)

 

2.    Information passively submitted. During your visits to the Website we collect certain information by automated means, including:

Category of Personal Data

Description

Legal Basis for Processing

System Data

Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types.

·      Performance of contract

·      Legitimate interests (service provisioning, customer and technical support, identity verification, communication, fraud prevention and security, product improvement)

Usage Data

Usage statistics about your interactions with the Website, including content accessed, time spent on the Website, pages visited, features used, and date and time.

·      Legitimate interests (service provisioning, user experience, product improvement)

Approximate Geographic Data

An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.

·      Legitimate interests (user experience improvement, fraud prevention and security, compliance)

The data listed above is collected using server log files and tracking technologies, like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (collectively, “Data Collection Tools”) when you access and use the Website. These Data Collection Tools automatically track and collect certain system data and usage data as described above when you use the Website. This data is stored by us and associated with your account.  You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Website, and your experience may be different or less functional. 

How we process and disclose your personal data

We may use the information you provide, including your personal data, in the following ways.

  1. To provide and administer content. We may use your personal data to process your requests and orders for content, products, and services, and to provide you with the content you access through the Website.
  2. To respond to your inquiries and communicate with you about your account. We may use your personal data to respond to your inquiries or to send you administrative messages and information about your account.
  3.  For marketing of products and services. We may use your personal data to carry out marketing of Customized Interactions products and services in which you have indicated an interest through our Website, provided that our legitimate interests in carrying out these marketing activities are not outweighed by any prejudice or harm to your rights and freedoms. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as described below.
  4. To improve our website. We use information passively submitted to improve the content, design, and navigation of the Website. In addition, we may use this information for analytics purposes (e.g., analyze site usage patterns, origin of traffic to the Website) so that we can gauge the effectiveness of our marketing programs. Such analysis and research activities may be conducted through third party services, using anonymous data and aggregate statistics. To the extent permitted by applicable law, we may combine the various types of information we collect.
  5. To defend our legitimate interests and to change our business structure. We may disclose personal data in connection with legal proceedings or investigations anywhere in the world to third parties, such as public authorities, law enforcement agencies, regulators and third-party litigants (these third parties are not data processors on behalf of Customized Interactions and will process personal data for their own purposes). We may also provide your personal data to any potential acquirer of or investor in any part of our business for the purpose of that acquisition or investment.

Disclosure and cross-border transfer of personal data

When you use the Website you are transferring information to the United States, and we may store your information, including any personal data you provide, on servers located in the United States, Ireland, and Germany. 

We have engaged various data processors for the processing of your personal data on our behalf, including payment processors, email and hosting services, and other business service providers. We have contracts in place with our data processors, which means that they cannot do anything with your personal data unless we have instructed them to do it. They will not share your personal data with any organization (unless legally required to do so) apart from us. They will hold it securely and retain it for the period that we instruct.

We may be legally required to disclose your personal data in response to requests from regulators and law enforcement or security agencies, in which case these regulators and law enforcement or security agencies will be acting as a data controller as well. We will always assess the legitimacy of such requests before disclosing any personal data and will only disclose the personal data required to comply with such request.

Our commitment to security

No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we have implemented appropriate technical and organizational measures to secure the processing of personal data. These safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the personal data, and include measures designed to keep personal data protected from unauthorized access. If appropriate, these safeguards include the encryption of communications via SSL, firewalls, access controls, separation of duties, and similar security protocols.

We restrict access to personal data to personnel and third parties that require access to such information for legitimate, relevant business purposes.

All our staff members, contractors and third parties who will have access to personal data on our instructions will be bound to confidentiality and we use access controls to limit access to individuals that require such access for the performance of their responsibilities and tasks.

Limiting collection and retention

We collect, use, disclose and otherwise process your personal data that is necessary for the purposes identified in this Privacy Notice or as permitted by applicable data protection regulations. Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the personal data was collected, and any other permissible, related purpose. For example, we retain your personal data where necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us.

Your rights 

We strive to maintain personal data that is accurate, complete and current. You can choose not to provide certain data to us, but you may not be able to use certain features of the Website.  

Where applicable, you have the following rights in relation to your personal data under the GDPR (please be aware that certain exceptions apply to the exercise of these rights and so you may not be able to exercise these in all situations):

1.    Right of access: you have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to obtain a copy of the personal data we maintain about you.

2.    Rectification: you may ask us to rectify any inaccurate personal data that we process.

3.    Erasure: you may ask us to delete personal data that we no longer have a legal ground to process.

4.    Restriction: you may ask us to mark certain personal data as restricted whilst complaints are resolved and also ask for restriction of processing under certain other circumstances.

5.    Portability: You can ask us to transmit the personal data that you have provided to us and we still hold about you to a third party electronically.

In addition, under certain conditions, you have the right to:

·       where processing is based on consent, withdraw the consent;

·       object to any processing of personal data that Customized Interactions justifies on the “legitimate interests” legal ground, unless our reasons for undertaking that processing outweigh any prejudice to the individual’s privacy rights; and

·       object to direct marketing at any time.

These rights are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you wish to exercise one these rights, please contact us using the contact details provided below.  To ensure an efficient follow-up, we kindly ask you to specify your request and to indicate to which personal data your request relates. 

California residents are entitled to certain rights relating to your Personal Data, including the following:

·       You have the right to request that we disclose certain information to you about our collection, use and/or disclosure of your Personal Data over the past 12 months.

·       You have the right to request the deletion of Personal Data that we collected about you and retained, subject to certain exceptions.

·       California residents wishing to submit a verifiable request to exercise these rights can do so (up to twice within a 12-month period) by contacting us using the contact details provided below.  In accordance with your rights under the CCPA, we will not discriminate against you for exercising any of your privacy rights under California law or applicable law.

For your protection, when you seek to exercise the rights described above, it will be necessary for us to verify your identity or authority to make the request (by matching the information provided in your request to information already in our systems) to confirm that the Personal Data relates to you. 

We do not sell Personal Data to a third party and have not sold Personal Data in the past 12 months. 

How to contact us

In case of any questions or requests in relation to our use of your personal data, you can contact Customized Interactions by:

·       emailing us at: info@CustomizedInteractions.com; or

·       writing us at: 7500 Rialto Blvd. Ste. 1-250 #229 Austin, TX 78735.

Changes to this Privacy Notice

This Privacy Notice is subject to change at any time. It was last changed on November 30, 2024. If this Privacy Notice changes, we will update the date it was last changed and publish the revised Privacy Notice on our Website. We advise all our Website visitors to regularly check for updates.

Terminology

Under the GDPR, the below terms have a defined meaning as set out in the table below:

GDPR: The European General Data Protection Regulation (EU) 2016/679. The GDPR is applicable in all EU member states as of 25 May 2018.

Personal Data: Any information relating to an identified or identifiable natural person (e.g. a person whose identity can be established reasonably without disproportionate effort by means of name, address and date of birth). By way of example but not limitation, any contact information, emails, IP addresses, user profiles, and transaction details.

Processing (of personal data): Any operation or any set of operations concerning personal data, including in any case the collection, recording, organisation, storage, updating or modification, retrieval, consultation, use, dissemination by means of transmission, distribution or making available in any other form, merging, linking, as well as blocking, erasure or destruction of personal data.

Data Controller: The legal person, administrative body or any other entity which, alone or in conjunction with others, determines the purpose of and means for processing of personal data.

Data Processor: The person or body which processes personal data on behalf of the data controller, without being subject to the data controller’s direct control.