Privacy Policy

 

1.   Introduction, Scope, and Responsibility of Handing of Personal Data

 

The Gales Group, LLC ("We" or "Us") is committed to protecting and respecting your privacy. This Privacy Policy (the “Policy”) describes the information about you (“Personal Data”) We collect and how We handle it when you visit www.https://www.transformationthroughtransaction.com/ and other websites operated by Us ("Site") and when you interact with Us.  As used in this Policy, the term Personal Data includes information that relates to an identified individual or to an identifiable individual. When you access our Site, contact Us, or make an inquiry, via our site or other means, your Personal Data and any other information you submit will be processed by The Gales Group, LLC.

 

2.   Types of Personal Data Collected and Means of Collection

 

  1. Personal Data you provide to Us. This is information about you that you provide to Us by filling in forms on our site or by corresponding with Us by phone, e-mail or otherwise. It includes information you provide if and when We meet with you in person. The types of Personal Data you give Us may include your name, address, e-mail address and phone number, and other information that you voluntarily provide. You should not provide and We do not need Personal Data that may be considered sensitive such as health information, financial account details, social security numbers or other government identifiers, or information about children as further detailed below.

  2. Information We collect about you. We may automatically collect the following information when you visit our Sites:

·      technical information about a device you use to access the internet and the Site, including the domain and host name of the device, the Internet protocol (IP) address of the device and information that may be derived from IP address such as geographic location, browser type and version, time zone and country setting, operating system and platform;

·      information about your Site visit, including pages and content you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

  1. Information We receive from other sources. We work closely with third parties (including, for example, marketing services agencies) that may provide Us with additional information about you.

  2. Information contained in cookies. The Site uses cookies to distinguish you from other users of the Site. This helps Us to provide you with a good experience when you browse our Site and also allows Us to improve our Site. For detailed information on the cookies We use and the purposes for which We use them see our Cookie Notice below.

 

3.   Why and How We Use Your Personal Data

 

  1. Information you give to Us. We will use this information:

·      to respond to your inquiries and provide information you requested; 

·      to fulfill obligations contained in an agreement between Us;

·      to provide you, or engage the services of a third party to provide you, with information about services We feel may interest you. We will only contact you by electronic means (e-mail or SMS) with information about services similar or related to those We previously provided to you or in which you indicated interest, or where you have consented to this, or where We can otherwise lawfully do so;

·      to notify you about changes to our service.

  1. Information We collect about you. We will use this information:

·      to administer our site and for internal operations, such as troubleshooting, data analysis, testing, research, statistical and survey purposes;

·      to improve our site to ensure that content is presented in the most effective manner for you and the device you use to access the Site;

·      as part of our efforts to keep our site safe and secure; or

·      to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you.

  1. Information We receive from other sources. 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).

  2. To comply with applicable laws and regulations and to operate our business. For all of the above types of information, in some cases, We have to process Personal Data to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process Personal Data in the performance and operation of our business, such as for finance, accounting, archiving, and insurance purposes.

 

4.   Sharing and Disclosure of Your Information

We may share your Personal Data as follows:

 

  1. Selected third parties including:

·      service providers, such as marketing services agencies, with which We have an agreement. These third-party service providers assist Us in maintaining our site, analyzing our site traffic, and in providing services and information to Us and to users of our site. We may also share your Personal Data with consulting and financial services providers. We may in certain situations obtain your consent before doing so; and

·      analytics and search engine providers that assist Us in the improvement and optimization of our site.

 

b.    We will also disclose your Personal Data to third parties:

·      In the event that We sell or buy any business or assets, in which case We will disclose your Personal Data to the prospective seller or buyer of such business or assets.

·      If We, or substantially all of our assets, are acquired by a third party, in which case Personal Data will be one of the transferred assets.

·      If We are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of The Gales Group, LLC or our customers, partners, providers, or others.

 

5.   Where We Store Your Personal Data and How It Is Protected

Personal Data will be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It will also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. By submitting your Personal Data, you agree to this transfer, storing or processing. We implement appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing. The security of transmitting information via the internet cannot be guaranteed and We make no such guarantees or warranties. Any transmission of Personal Data is at your own risk. 

 

6.   How Long We Retain Your Personal Data

We retain Personal Data for so long as it is necessary to fulfill our obligations as set forth in this Policy, not to exceed three (3) years, except as otherwise set forth in this Policy. 

 

7.   Choices You Have Regarding Handling of Personal Data

Applicable laws may provide you with certain choices regarding how We handle your Personal Data. 

a.    For example, you may be able to request:

·      a copy of your Personal Data We hold, including a copy in machine-readable form;

·      the rectification or erasure of some of your Personal Data We hold;

·      that We restrict the processing of your Personal Data (while We verify or investigate your concerns with this information, for example), or you can object to the further processing of your Personal Data, including the right to object to marketing.

b.    Where the processing of your personal information by Us is based on consent, you have the right to withdraw that consent at any time by contacting Us at privacy@transformationthroughtransaction.com.

c.     You can also exercise the rights listed above at any time by contacting Us at privacy@transformationthroughtransaction.com.

d.    If you have any questions or complaints regarding our compliance with this Policy, please contact Us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with this Policy and applicable law.

e.    You also have the right to file a complaint with a competent data protection authority if you are a resident of a European Union member state.

 

8.   Legal Basis for Processing

 

This site is not directed to individuals located outside of the United States, but in the event you are located in the European Union, our basis for processing your personal data includes:

 

  • In order to communicate adequately with you and to respond to your requests, We need to process your Personal Data and therefore have a legitimate interest in processing this information.

  • In order to provide you services you request, We need to process your Personal Data as necessary to enter into or perform a contract with you.

  • We process Personal Data for marketing activities based on your consent where so indicated on our Site at the time your Personal Data was collected, or further to our legitimate interest to market and promote services.

  • We rely on our legitimate interest to analyze, develop, improve and optimize our Site, services, and to maintain the security of our Site and systems.

  • In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

 

9.   Other Sites

 

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please review these policies before you submit any Personal Data to these websites.

 

10.                 Information about Children

 

We focus on serving the needs of businesses and business owners. Accordingly, the Site is not directed to minors and We do not promote or market our services to minors. If you believe that We have mistakenly or unintentionally collected Personal Data of a minor through our Site without appropriate and legally-required consent, please notify Us as set forth in this Policy so that We may immediately delete such information from our systems and take other action that may be necessary. 

 

11.                 Changes to our Privacy Policy

We may modify this Policy from time to time. Any changes We make to this Policy will be posted on this page and will be effective as of the date of publication (which will also be noted on our website).  This Policy was last updated September 30, 2019.

 

12.                 Cookie Notice

 

Our Site uses or may use the following cookies:

 

a.    Functional Cookies: these are cookies that are necessary for the operation of the Site. You can block these cookies, but the Site may not operate correctly.

b.    Performance Cookies: these are cookies that help Us understand how visitors interact with the Site and how the Site performs. If you block these cookies, We will not learn about any performance issues with the Site in order to make it operate better.

c.     Marketing Cookies: these are cookies we may use to help Us or our partners deliver targeted advertisements to you online. If you block these cookies, you will still receive advertisements online, but they will not be targeted or tailored to you.

 

The Site does not respond to Do Not Track (DNT) signals. A number of governments, industry groups, and technology companies have been working on a DNT technology standard, but nothing has been adopted to date. 

 

You may block or turn off certain cookies using your browser settings, but based on the types of cookies used above, the Site or other related functionality may not work correctly.

 

13.                 Contact

Questions, comments, or requests regarding this Policy should be addressed to privacy@transformationthroughtransaction.com.