Website Privacy Policy

Introduction

This privacy policy describes the types of information we may collect from you or that you may provide when you visit the Website and our practices for collecting, using, maintaining, protecting, and disclosing that information (“Privacy Policy” or “Policy”). Any capitalized terms herein that are not defined shall have the meaning defined in the Company’s Terms of Use located here.

The Company respects your privacy and is committed to protecting it through our compliance with this Policy. This Policy applies to information we may collect:

On this Website.
In email, text, and other electronic messages between you and us.
Through mobile and desktop applications you download from 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 Company or any third party [(including our affiliates and subsidiaries)]; or
Any third party [(including our affiliates and subsidiaries)], including through any application or content (including advertising) that may link to or be accessible from or through the Website.

User Consent

By engaging with or using the Website, you consent to the terms of this Privacy Policy. If you do not agree to the terms and conditions of this Policy, including having your “Personal Information” used in any of the ways described herein, then do not use the Website. The Company has the right to change this Policy at its discretion. In the event we materially change how we use your Personal Information, where required by law we will (as applicable) (i) provide you with the Policy and ask you to affirmatively accept these material changes, and/or (ii) provide you with notice of the change and the date of implementation of the revised terms. Use of the Website by you or your designees following our posting of a new Privacy Policy on the Website constitutes your acceptance of the Privacy Policy as modified.

Children Under the Age of 13

The Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

Information We Collect About You and How We Collect It

You may voluntarily provide us with personal information when you book a service with us, contact us for customer support, or otherwise provide us with personal information. 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, email address, telephone number, and credit card information ("personal information");
By which you provide to us pertaining to demographic information, such as gender, age, or birthdate.
Understood to be personal information under the specific laws of different states and or countries. For instance, in the UK and EU, this kind of personal information is referred to as “personal data”. In the United States it is referred to as “personally identifiable information.” In California it is referred to as “personal information.”

We may 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, web beacons, and other tracking technologies.

Information You Provide to Us

The information we may 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 booking a service or subscribing to our weekly mail. We may also ask you for information when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.

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 may collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. 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.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we may 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.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie non-personal information collected automatically to personal information about you that we collect from other sources or that you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies [alone or in conjunction with web beacons or other tracking technologies] to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly

How We Use Your Information

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

To provide our services to you;
To process payments and booking services;
To provide you with customer support;
To maintain, improve, and personalize your experience of our Website
To monitor our Website for compliance with our Terms of Use;
To provide you with marketing materials about new products and services that you may be interested in from us, our affiliates, and other third parties;
For our analytics, research, record keeping, and reporting purposes; and
As otherwise disclosed at the time of collection.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Correcting Your Information

It is your obligation to update the Company with any changes to the information provided to us. To update any information made available to us, please contact us at: hello@congruentleadership.com

Disclosure of Your Information

We will not disclose personally identifiable information we collect from you to third parties without your permission except to the extent necessary including:

To our subsidiaries and affiliates.
To service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To fulfill the purpose for which you provide it. For example, credit card information provided to us by you to process payments for Services, personal contact information for booking appointments, etc.
In connection with a merger, acquisition, or liquidation of the company.
For any other purpose disclosed by us when you provide the information.
With your consent.

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.
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, its affiliates, agents, owners, customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

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.
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Residents of certain states, such as California, may have additional personal information rights and choices. The following is an example of specific California state law privacy rights. We make no representation that this Policy complies with laws and regulations applicable to you including in your State. Nothing herein is intended to represent such compliance, and we urge you to review your state’s privacy laws.

California Residents:

If you are a resident of the State of California, you have the right to be informed about the Website’s practices regarding the collection, use, disclosure, and sale of your Personal Information. Pursuant to the California Consumer Privacy Act (“CCPA”), you have the right to request disclosure and deletion of your personal information, the right not to be discriminated against for exercising your California privacy rights, and the right to opt-out of the sale of your personal information. We do not sell the Personal Information of California consumers, and we do not discriminate in response to privacy rights requests.

If you are a California resident, and you do not want us to share your personal information with third parties for their direct marketing purposes, or if you would like to request disclosure of information about you that we have collected, please contact us at the following address: hello@congruentleadership.com

Privacy Rights for Data and Personal Information Collected from EU Residents

This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). The term “Personal Information” as used in this Privacy Policy means “personal data” as defined under Regulation (EU) 2016/679 (General Data Protection Regulation, or “GDPR”).

Under GDPR, the Company is both a “Controller” and a “Processor.” The Company is the Controller of Personal Information you provide to us about yourself as a customer or when requesting information about our products and services. For data you provide to the Company or request that we collect as part of using our Services, including but not limited to the Personal Information we collect on behalf of our customers, we are a Processor for our customers, who are the Controllers that determine the purposes and means of the processing of your Personal Information by the Company.

The Company is based in the USA. Personal information and data processed by the Company is transferred to our servers in the USA. When transferred, we take all reasonable steps to protect your Personal Information, including encryption during data transit and storage. For more information, see “International Data Transfers and our Privacy Shield Compliance” below.

How Your Personal Information is Used

Your data may be used in a variety of ways. As a Controller, we collect and use your Personal Information to respond to inquiries or provide the products and services you seek to obtain from the Company. As a Processor, we do not transfer Personal Information to third parties except we may in the future sell to the companies in which case we will update to include them on our list of sub-processors, and then only in order to provide the services requested by our customer.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity
(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Your Privacy Rights as a Subject of the EU

Subject to applicable law and reasonable steps that we may take to verify your identity with respect to your requests, you have the following rights in relation to your Personal Information:

Right to be informed: organizations must tell individuals what data of theirs is being collected, how it is being used, how long it will be kept and whether it will be shared with any third parties.
Right of access: individuals have the right to request a copy of the information that an organization holds on them.
Right of rectification: individuals have the right to correct data that is inaccurate or incomplete.
Right to be forgotten: in certain circumstances, individuals can ask organizations to erase any personal data that is stored on them.
Right of portability: individuals can request that an organization transfer any data that it holds on them to another company.
Right to restrict processing: individuals can request that an organization limits the way it uses personal data.
Right to object: individuals have the right to challenge certain types of processing, such as direct marketing.
Rights related to automated decision making, including profiling: individuals can ask organizations to provide a copy of its automated processing activities if they believe the data is being processed unlawfully. You should also remind individuals that they are free to exercise their rights and explain how they can do this.

If you have an account with us, we may instruct you to exercise some of your rights above through account settings or features, or by deleting your account.
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EU Data Subjects may contact us to exercise the rights above at support@stemlins.com.

Data Security

We take reasonable physical, administrative, and technical steps to help maintain the data we collect in a secure manner. The user information we collect is stored and processed in manners to allow only authorized individuals to access the infrastructure where this information is stored. We take great care to maintain commercially reasonable standards of data security and protection and continues to implement those measures for our infrastructure where user information is stored. We maintain strict administrative, technical, and physical measures designed to safeguard the information we process. We use industry-standard SSL encryption when collecting or transferring your information. Other safeguards include but are not limited to data encryption, firewalls, multi-factor authentication for our personnel with access to your information, and physical-access controls

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention

Contact Information

If you have questions regarding our Privacy Statement, its implementation, failure to adhere to this Privacy Statement and/or our general practices, please contact us at hello@congruentleadership.com or send your comments to:

Julia Quijano, LLC
Attention: Privacy Statement Personnel
11693 San Vicente Blvd. #904
Los Angeles, CA 90049

The Company will use commercially reasonable efforts to promptly respond and resolve any problem or question.