Thank you for visiting our website, https://ispeakclearly.com, (“Site”). iSpeak Clearly, Inc. (“Company”) is committed to treating the personal and corporate information of our Site users, customers, and vendors with respect and sensitivity.
We’ve updated our Privacy Policy and improved our privacy practices so we can better safeguard your data. This Site also uses cookies to personalize your experience and target advertising. By continuing to use our Site, you accept the terms of this Privacy Policy and our Terms of Use.
This Privacy Policy (together with our Terms of Use and any other policies referenced) identifies how we will collect and process any personally identifiable information, such as your name, email, address, financial account information, etc., that we collect from you, or that you provide to us.
If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any CCPA-specific information is identified in this Policy.
If you are a resident of the European Economic Area (“EEA”), this Privacy Policy also outlines additional policies applicable to our collection and processing of your personal information.
As our services evolve and we perceive the need or desirability of using your personal data collected in other ways, we may from time to time amend this Privacy Policy. The effective date appears at the end of this Privacy Policy. We encourage you to check our Site frequently to review
the current Privacy Policy in effect and any changes that may have been made to it.
By providing your Personal Information to us in any format (e.g., via email, telephone, fax, or in person) and/or continuing to use any of our services or visiting our Site you accept and consent to the practices described in this Privacy Policy.
This Privacy Policy describes how the Company collects, uses, and shares information about visitors to our Site, attendees of our programs, individuals who contact us to purchase materials or request information, and other users of our services. The Site and our other programs and services are the “Services.” This Policy describes how we obtain and use personal data (which can be used to identify a specific individual) and anonymous data (which cannot).
Region specific provisions. Certain provisions of this Policy, which are clearly labelled, apply only to users who are citizens or residents of particular regions (e.g., the EU or California). Otherwise, the Policy applies to all users of our Services, regardless of location.
Children. The Services of the Company are not directed to children. If you become aware that a child (based on the jurisdiction where the child lives, which in the United States means someone under the age of 13) has provided us with Personal data without parental consent, contact us at info@ispeakclearly.com or annemarie@ispeakclearly.com.
We collect personal information that you enter on our Site or otherwise volunteer to us when you contact us to, among other things, make purchases, request information, or register for or attend our programs. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features.
For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal Information comprises the categories of Personal Information defined by the CCPA, which includes:
Identifiers
Name, address, email, phone, SSN, driver’s license
Other Data
Financial information, medical information, health insurance information
Protected Classes
Race, gender, sexual orientation, religion
Commercial Information
Records of personal property, purchasing or consuming histories or tendencies
Biometric Information
Fingerprints, retina scans, face prints
Internet Activity
Browsing history, search history, IP address, website interactions
Geolocation Data
GPS coordinates, location history
Sensory Data
Audio, electronic, visual, thermal, olfactory
Professional Data
CV, resume, employment history
Education Data
Educational background, grades, scores
Inferences
Drawn the above categories, such as preferences, characteristics, attitudes, predispositions, abilities, aptitudes,
intelligence, psychological traits
The examples given in this table are not meant to provide an exhaustive list but are examples of the kinds of data included in each category. Company does not collect Personal Information in every one of these categories, and we identify below which categories we collect.
Personal Information under the CCPA also includes any other category of personal information not included within the CCPA’s definition that are defined in California Civil Code § 1798.80(e). We refer to this category as “Other Data,” and it includes information such as financial information (bank account number, credit card number, debit card number), medical information, health insurance information, and insurance policy number.
Our Company collects only that Personal Information that is relevant for the purposes for which the data is requested. The Company does not use your Personal Information in any way that is incompatible with the purposes for which it was collected or for which you have consented.
When you contact us through our Site, or by corresponding with us by phone, e-mail, or otherwise, or attend a Company event, we may collect Personal Information including:
Identifiers: First and Last Name and Email Address.
We do not collect or receive Biometric Information or Sensory Data.
This is information we receive about you from third parties who operate other Sites or services we use in order to provide our products and services to you. We work closely with third parties, including, for example, business partners, promoters, affiliates, and sub-contractors in technical, payment and delivery services, advertising networks, marketing analytics providers, promotions, and search information providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We will use this information:
We will use this information:
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
To provide the Services, we sometimes disclose Personal Information to service providers for business purposes. Sometimes we disclose your Personal Information to those third parties, and they sometimes collect your Personal Information in the first instance and provide it to us.
Our service providers are contractually obligated to comply with all applicable laws (e.g., the CCPA), and all such third parties use your Personal Information only on behalf of Company and under the instructions of Company on how your information may be used and processed. Company takes reasonable steps to ensure these third parties use your Personal Information only for the purposes for which they have been engaged by Company, that they do not share or sell your Personal Information to anyone else.
By enjoying our Services and sharing your Personal Information, you agree that we have the right to share the categories of Personal Information we collect, as identified in Section 2 with our service providers for the following business purposes:
We may also disclose your personal information to third parties in the following circumstances:
Whenever we share information with third parties, we will take reasonable steps to ensure that the third parties put in place adequate measures to safeguard your Personal Information, and they will be required to use any Personal Information for only the intended purpose for which it was shared.
Company uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect.
We will keep your personal data for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.
You may unsubscribe from any of our online e-mail updates and marketing by following the unsubscribe instructions in the body of any e-mail message we have sent to you. We utilize Mailchimp for all of our subscriptions. Once you unsubscribe, you may still receive promotional information from us by email for up to ten (10) days. You may also continue to receive information from those third parties to whom we have previously disclosed your Personal Information.
Please note that when you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
To submit a request to know about the Personal Information we collect about you as described in Section 8.1 or a request for deletion of your Personal Information as described in 8.2, please contact us by emailing us at info@ispeakclearly.com or annemarie@ispeakclearly.com .
Company is required to verify the identity of the individual requesting access to a consumer’s data or requesting deletion of a consumer’s data. To verify your identity, you must provide: First and Last Name and Email Address.
California consumers may designate an authorized agent to exercise a CCPA right on the consumer’s behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer’s behalf will need to be provided:
THE FOLLOWING ADDITIONAL DEFINITIONS APPLY TO THIS SECTION OF THE PRIVACY POLICY:
“Controller” means the Company which is the organization that determines the purposes for which, and the manner in which, any Personal Information is Processed and used in its business.
“Processor” means any Person Processing Personal Information.
“Person” means a natural person, corporation, association, organization, partnership, or other legal entity.
“Processing” is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording, or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring Personal Information to third parties.
In order to comply with the GDPR, we are required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for processing your Personal Information will typically be one of the following:
The data that we collect from you is stored on our servers or on servers provided by cloud service providers, such as Google Analytics. If you are a resident of the EEA, your Personal Information may be transferred within or outside the EEA to areas where privacy laws may be less strict than in the EEA (for such transfers of your Personal Information to our systems in the United States, we comply with the US-EU Privacy Shield Framework and Swiss-US Privacy Shield Framework). By submitting your Personal Information, you agree to this transfer, storing, and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Subject to certain exceptions, you have the following rights with respect to your Personal Information:
All of these rights are subject to certain conditions and exemptions. For example, Company will not be obligated to erase your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.
To exercise any of these rights, please submit a written request to us using the contact information set forth below. The Company reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.
This Site is owned and operated by Company. If you have any questions or suggestions with respect to this Privacy Policy or our privacy practices, please email us at annemarie@ispeakclearly.com or info@ispeakclearly.com.
Effective Date: April 6, 2023
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