Privacy Policy

I am committed to the protection of your privacy.   By using the thrivewithmorella.com (Site), you are agreeing to be bound by this policy.  This policy explains how I collect, use and store the personal information you provide to me.  I may amend this policy at any time.  

Some of the information below might be a little technical but it's important that you read and understand what follows because it explains how I will collect and use your personal information. 

1.  What I collect and how I collect it  

The personal information I collect about you depends on the dealings you have with me. Personal Information includes information about an individual who is reasonably identifiable. For example, if you: 

a.              send me an enquiry or provide me with feedback through my online form or via email or phone, I will collect your name, contact details, details of your enquiry or feedback and information about my response; 

b.              register to receive an offering on the Site, such as an e-book or other free information, you will be asked to complete a registration form and provide personally identifiable information; 

c.              register on the Site, you will be asked to complete a registration form and provide personally identifiable information. You may also be asked to choose a user ID and password in order to take advantage of certain features on the Site or digital messaging services, such as newsletters or contests.  Your decision to register is voluntary and you will have the opportunity to decide whether or not to disclose information to me and what communications you would like to receive; however, please note that products and services available on the Site may require registration and if you elect not to provide such information, you will not be able to take advantage of those products and services; 

e.              make a purchase online, I will collect your name, contact details, order details, credit card details, delivery address and I may also ask you to provide your date of birth and gender; 

f.               provide information via social media pages such as providing your name or contact details via any of my  social media accounts; 

g.              engage with or purchase products from third parties who deal with me, such as any affiliates I may have from time to time, or through third parties; 

j.                carry out assessment and analysis (for example market, customer and product analysis) to enable me to review, develop and improve the products or services which I offer. 

I may also collect information that cannot be used to directly identify you, such as browser type, Dynamic Internet Protocol (IP) address, “click stream” data, and similar non-personally identifiable information.  For example, I may aggregate non-personal information about you and other customers who visit certain areas of my Site.  Aggregated information will not contain any information that can be linked directly back to you. 

By using the Site, you agree that you do not object to me using your personal information for any of the purposes outlined in this policy and you confirm that you do not and will not consider any of these purposes as a breach of any of your rights under applicable privacy laws. 

2.  Collection of personal information through websites  

Information is automatically collected through your use of the Site, and affiliates’ websites (if any), through cookies. Cookies are tiny text files that websites or apps may place on your computer or device.  

I may collect this information both anonymously and in relation to user accounts. The information is used and disclosed by me for purposes including statistical analysis and to assist me to improve the functionality and usability of the Site and to personalize your Site experience. For example, when you visit the Site, I may use cookies to record information including your IP address, the date and time of your visit, the pages you viewed, any documents you downloaded and the type of browser and operating system you used. You do not have to accept my cookies and you may delete them after they have been placed on your hard drive.  

Third Party Cookies

I try to make it as easy as possible for you to share the content I have on the Site. I have added buttons to allow people to easily share on networks like Facebook and Twitter.

Please note that when I include social ‘plugins’, it gives those social networking site the flexibility to use cookies. They can't read any cookies I set from the Site, and I can't read any cookies they set, but it lets them do the same kind of traffic measuring that I do on the rest of thrivewithmorella.com, and it also lets them know whether you're logged in. For example, if you're logged in to Facebook, read one of my posts and want to make a comment, you can do that straight away without having to log in to the Site again - I never know whether you're logged in or not, as you communicate directly with Facebook, through their plugins on my site.

I don't control the setting of these third-party cookies, so I suggest you check the third-party websites for more information about their cookies and how to manage them.

Other sites and services (including, for example, advertising networks, providers of external services like web traffic analysis services and content recommendation engines) may also use cookies, over which I have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

My internet service providers may also use other standard web-based technologies to analyze your movements while accessing the Site. The technologies include analytic solutions, web “beacons,” “pixel tags,” and “clear gifs.” These technologies help me ascertain the effectiveness of the Site, allow me to customize Content, and help determine the best use for Site Content. Some of this information, including the IP address, may be stored on my internet service provider’s server logs, and may be available for extended periods of time.

How do I turn cookies off? 

If you do not wish me to install cookies or you don’t agree with how I use cookies in any way, you can change the settings on your internet browser to delete or do not accept cookies. Please be aware that if you delete or do not accept my cookies, some areas of the Site that you access may take more time to work, or may not function properly. For more information about cookies please visit: http://www.allaboutcookies.org.   

3.  Why I collect personal information 

Main purposes 

The main purposes for which I collect, hold, use and disclose personal information are: 

a.              processing transactions and delivering products and services; 

b.              promoting my products and services; 

c.              performing research and statistical analysis, including for customer satisfaction and product and service improvement purposes; 

d.              helping me tailor existing or develop new products, services or offers, and to help me selectively target promotional offers and opportunities; 

e.              developing or seeking to deliver new ranges of products or services; 

f.               answering queries, resolving complaints and responding to social media; and

h.              general planning and administration. 

I may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or which are required or authorized by or under law, and for which you have provided consent. 

Direct marketing and opting out  

By providing your address and email address to me you consent to me contacting you for the purposes set out above. I may send this information in a variety of ways, including by mail, email, and social media.  

If at any point you no longer wish me to hold your personal information or you do not wish to receive information from me then there are a number of ways you can unsubscribe:  

a.              contacting me by email at mdevost@transformationone.com or by calling me at +1.802.489.5379; or

c.              using the unsubscribe link that I include in my electronic messages (eg email) to opt out of receiving those messages. Each "unsubscribe" link only relates to that specific type of communication (e.g. marketing communications or survey communications). This means that unsubscribing from marketing communications will not automatically unsubscribe you from my survey communications (or vice versa). Please also note that you may continue to receive communications which are already en route to you for a short period of time while your relevant unsubscribe request is being processed. 

4.              Who I may share your personal information with  

I may share your personal information with third parties where appropriate for the purposes set out above, including: 

a.              financial institutions for payment processing; 

b.              contracted service providers or partners, including: information technology service providers; research and statistical analysis providers; external business advisers (such as auditors and lawyers); and regulatory, investigative or government bodies to comply with laws. 

I may also disclose your personal information as is necessary to: (a) comply with a subpoena or court order; (b) cooperate with law enforcement or other government agency; (c) establish or exercise my legal rights; (d) protect my property or safety or that of my employees, contractors, vendors, and suppliers; (e) defend against legal claims; (f) help with internal and external investigations; or (g) as otherwise required by law or permitted by law.  

5.  Data quality and security 

General  

I hold personal information in a number of ways, including in printed documents, electronic databases and email contact lists. Printed documents may be held at my office, or archived in boxes and stored in secure offsite facilities. I take reasonable steps to: 

a.              ensure that the personal information that I collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant; 

b.              protect the personal information that I hold from misuse, interference and loss and from unauthorized access, modification or disclosure; and

c.              destroy or permanently de-identify personal information that is no longer needed for purposes permitted by applicable privacy laws. 

You can help me keep your information up to date, by letting me know about changes to your details. 

Security  

The steps I take to secure personal information include website protection measures and security restrictions on access to my computer systems. While I endeavor to protect the personal information of users of my website, I cannot guarantee the security of information you disclose online: you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact me as set out in section 10. You can also help protect your personal information by keeping your account details confidential. If you become aware of any security breach, please let me know as soon as possible. 

The Site makes commenting functionality available to you and other users. You are not required to provide any personal information when using these areas but you may choose to do so. If you post personal information online, it will be publicly available and you may receive unsolicited messages from other parties.  

By using the commenting features of the Site, you acknowledge that your user name and location information will be disclosed. I cannot ensure the security of any information you choose to make public in a comment. Also, I cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in any comments. To request removal of your personal information from my blog, contact me at: mdevost@transformationone.com. In some cases, I may not be able to remove your personal information, in which case I will let you know if I am unable to do so and why. 

Third party sites  

Links to third party sites (if any) that are not operated or controlled by me are provided for your convenience only and should be used with your discretion and prudent judgment. I am not responsible for the privacy or security practices of those sites, which are not covered by this policy. Third party websites should have their own privacy and security policies, which I encourage you to read before supplying any personal information to them.  Links from my Site to third-party sites do not constitute sponsorship, endorsement, or approval of the content, policies or practices of such third-party sites. 

6.  Access and correction 

General  

Please contact me if you would like to access or correct the personal information that I hold about you. I may ask you to verify your identity before processing any access or correction requests, to make sure that the personal information I hold is properly protected. 

Access  

I will generally provide you with access to your personal information within 30 days, subject to some exceptions permitted by law. I will also generally provide access in the manner that you have requested (eg by providing photocopies or allowing a file to be viewed), provided it is reasonable and practical for me to do so. I may, however, charge a fee to cover my reasonable costs of locating the information and providing it to you. 

Correction  

If you ask me to correct personal information that I hold about you, or if I believe that the personal information I hold is inaccurate, out of date, incomplete, irrelevant or misleading, I will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. If I correct personal information about you, and I have previously disclosed that information to another agency or organization, you may ask me to notify that other entity. If so, I will take reasonable steps to do so, unless this would be impractical or unlawful. 

7.  Cross Border Disclosure Access and Consent to Transfer 

I may disclose personal information to overseas recipients, who are located in places such as Japan, Singapore, India, Hong Kong, the Philippines, the United States of America and other countries or jurisdictions depending on the nature of the services those recipients provide to me (for example storing data via a cloud service, or where my customer relationship management system is hosted on servers located overseas). 

By providing me with your personal information, you consent to my use of it in accordance with this policy, including the transfer of your information across international boundaries to jurisdictions anywhere in the world as permitted by local law.  

For United States Users:   

The United States may not have data privacy laws that are deemed to afford an equal level of protection for your Personal Information as those laws legislated at the direction of the European Union, Australia or geopolitical, national or regional legislative bodies. However, please be assured that I will continue to adhere to the principles stated in this policy and will make reasonable efforts to comply with applicable international, national, regional, territorial, and provincial laws in connection with any information collected through the Site. I will always endeavor to preserve the integrity, confidentiality, and security of personal information and afford such personal information reasonable level of protection. 

Your California Privacy Rights:  

Other than as is stated by this policy, I will not share any personal information about you with outside third-parties for their direct marketing purposes to the extent prohibited by California law, unless you agree otherwise as authorized by your prior written consent. 

California residents have the right to request information from me regarding the manner in which I may share personal information with third parties for their direct marketing purposes.  To find out what and how I share such information, you may send me an e-mail request at: mdevost@transformationone.com or call me on +1.802.489.5379.  You will receive the following information: 

1.              Information regarding the categories of information I disclosed to third parties for their direct marketing purposes during the preceding calendar year, if any; 

2.              The names and addresses of the third parties who received information for their direct marketing purposes; and

3.              Examples of the products and services subject to the third-parties’ direct marketing programs, if the nature of the third parties’ business cannot be determined from their names. 

8.  Data Retention Periods 

I will retain your personally identifiable information for as long as your account is active or as needed to provide you with my products and services. If you wish to cancel your account or request that I no longer use your information to provide you with my products and services, please contact me at mdevost@transformationone.com. However, I will retain and use your information as necessary to comply with my legal obligations, resolve disputes, and enforce my agreements. 

9.  General Audience Website Not Directed Toward Children 

Protecting the online privacy of children is especially important to me. The Site is a general audience site. My content is neither directed toward minors nor children who are under the age of 13. I do not knowingly collect personal information from children under the age of 13. If you are under 18 years old, please do not provide me with your name, contact details or any other information about yourself.  

If I or my internet service providers become aware that a minor or a child under the age of 13 has provided me with personal information without the parental consent, that information will be deleted from my databases. Parents who have questions about personal information that may have been submitted by a child under the age of 13 should email me at:  mdevost@transformationone.com. 

10.  Complaints or Questions  

I hope everything is explained here clearly but if you would like further information about how I manage your personal information, or if you have any queries relating to my policy, or wish to lodge a complaint in relation to an alleged breach of applicable privacy laws, please contact me by: Email: mdevost@transformationone.com or Telephone:  +1.802.489.5379.  All complaints received by me will be dealt with fairly and in a timely manner considering all the circumstances of the complaint. In most cases, I expect that complaints will be investigated and a response provided within 30 days of receipt of the complaint. If the matter is more complex and my investigation may take longer, I will contact you and tell you when we expect to provide my response. 

11. Changes to this Policy  

I may amend this policy from time to time. Please check back frequently to see any updates or changes to my policy.  If I make a material change to the way in which I collect, use, and/or share your personal information, I will post a notice on the Site and/or send an email to users who have provided an email address. Please note that you should always update your personal information to provide me with a current email address. 

The current version will be posted on the Site.  

Effective Date:  1 March 2017