We may change provisions of this Policy from time to time and will indicate when changes have been made by revising the date at the top of this Policy. We encourage you to review the Policy whenever you access the Services to make sure that you understand our practices. If we make material changes to this Policy, we will provide you with additional notice.
It’s important that you read the following carefully to understand our practices. Please also review the Terms of Service Agreement.
If you have any questions or unresolved privacy concerns, please contact us at [email protected]
Data Protection Across the Globe
Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply common protections described in this policy. These protections align with well-known standards such as ISO 27001:2017 and others.
Information Collection & Use
Information that you provide to us: We may collect information that you provide when using our Services, such as when you:
(1) create an account or profile;
(2) subscribe to our Services;
(3) participate in events or promotions;
(4) send questions or comments via email or live chat;
(5) interact with our sales or customer support team;
(6) apply for a job with us online;
(7) fill out surveys, quizzes or assessments;
(8) use any feature in our apps;
(9) purchase from us, claim a free bonus or create a guest, gift or free account;
(10) visit our websites; or
(11) otherwise communicate with us or any other person through or about our Services.
The types of personal information that you provide or may be collected may include but is not limited to your device ID, name, email address, telephone number, mailing address, credit card information, location, device type, log data, browser or network connection type, operating system, and other contact or identifying information that you choose to provide.
We store, process, and maintain files and content that you create and/or upload using our Services, as well as other data related to your account in order to provide the Services to you.
We do not store your credit card information on our servers but rather use secure 3rd parties like Stripe, Paypal or Apple integrations to process secure payments. We only ask for credit card information to complete and satisfy our rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by you, and in that case we use Stripe, Apple, or Paypal as our secured payment partners.
Information about use of our Services: Our app, providers or cloud servers automatically collect usage information about your use of the Services, including the webpages visited, number of log-ins, data displayed or clicked on, actions taken, your language preference, device id, and other login information. We may collect automated error reports in the case of software malfunctions, which may contain some or all of the information in your account and content and may be reviewed to help resolve problems with the Services.
If you participate in a livecast or video conference with us, we may record the session and retain the recordings, and you should assume we are since our interactions are part of the Services. We own any content that you appear in and may feature, sell or create content from it. If you participate in a training or product course, we collect user information and completion data.
We collect information from the device and application you use to access our Services. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, and browser type. If you are on a mobile device we also collect the UUID for that device.
We use a variety of technologies to collect this information, such as first party and third party cookies and tracking services that employ cookies and page tags (also known as web beacons). This data includes usage and user statistics. Emails sent by Luke Harlan Coaching or by users through our Services also include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We provide more information on cookies below.
We also use Facebook and other providers to place “pixels” on many of our sites or apps so that we can understand your digital behavior and potentially later target you with related advertising. We also use Google Analytics to understand how long you might spend on our Sites or how you interact with our Services. If you ever choose to opt-out of targeted advertising with us, then please contact us at [email protected] so that we can potentially remove your email, data or profile from any advertising we may use.
Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.
If you arrive at Luke Harlan Coaching from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
Information from third parties and integration partners: We may obtain personal information from third parties and combine such information with the information that we collect through our Services and such information may be used for the purposes described in the “How We Use the Information We Collect” section below. For example:
- You give permission to those third parties to share your information with us or where you have made that information publicly available online.
- You create or log into your account through a third-party social networking site or one of our integration partners, we will have access to certain information from that service such as your name and account information.
- You purchase an offer that comes with a free group coaching session or other coaching fulfillment that requires us to share your contact with the fulfillment provider.
- If you purchase our Services, we may receive information from our third-party payment processors.
- We may collect information from unaffiliated third parties so that we can better understand you and provide you with information and offers that may interest you.
How We Use the Information We Collect
Use of Information: We may use the personal information collected through our Services to:
- Operate and improve our Services;
- Send you recommendations, advertising or promotional materials;
- Provide and deliver the Services or other services you request, process transactions, and send you related information;
- Send you technical notices, updates, security alerts, and support and administrative messages;
- Respond to your comments, questions, and requests and provide you with requested customer support;
- Enable you to participate in 3rd party promotions, including trials or other bundled offers exclusive to our users, and to help us and our marketing partners to measure the effectiveness of our or their promotions.
- Monitor and evaluate trends, usage, and activities in connection with our Services;
- Secure our systems, prevent fraud, and help us to protect the security of your account;
- Prevent, detect, and investigate potentially prohibited or illegal activities and to enforce our terms and policies;
- Personalize and improve the Services, and provide content, communications, or features that match users interests; and
- Link or combine with other information we obtain from third parties to help understand your needs and provide you with better service.
- Connect you with a coach or service as part of your free group coaching bonus that comes with some offers.
- When you provide your phone number to us, we may use your phone number to confirm orders, deliver promised ongoing training or communication, and to send text updates, promotions, videos, audios, or sms messages related to Luke Harlan Coaching services, or related brands or programs. You can opt-out of receiving any future text messages by simply replying to any of our text messages at any time with the word STOP. By signing up for our Services, you hereby grant us permission to text you until you reply STOP.
We reserve the right at all times to review your content and information to help resolve problems with our software or Services, or to ensure that you remain in compliance with our Terms of Service.
Information we may share: We will never “sell” your personal information (as that term is defined in the California Consumer Privacy Act). However, we may share your personal information with third parties as follows:
- Service Providers: We use other companies, agents, or contractors to perform services on our behalf or to assist us with the provision of services to you. For example, we engage service providers to provide marketing, advertising, coaching, training, communications, security, payment processing, infrastructure and IT services, to customize, personalize, and optimize our Services, to process payment transactions, to provide customer service, and to analyze and enhance data. While providing such services, these service providers may have access to your personal information. These service providers have agreed to maintain the confidentiality, security, and integrity of the personal information that they obtain from us and we do not authorize them to use or disclose your personal information except in connection with providing their services.
- Other Users: Content that you create, upload, or copy into our Services, may, if you choose, be read, copied, used, and distributed by people you know, your members, or people you don’t know. Information that you disclose using the chat function of the Services may be read, copied, used, and distributed by people participating in the chat. Use care when including sensitive information, such as home addresses or phone numbers, in content you share or chat sessions.
- With Your Consent: We may share your personal information when we have your consent.
- Your Profile. You may share information on your profile in the app, comments or related social media that others can see.
Social Media and Public Forums: Luke Harlan Coaching Services may include publicly accessible blogs, chats, comments, community forums, or private messaging features. Our Services may also contain links and interactive features with various social media platforms (e.g., Facebook, Instagram, YouTube, Twitter and the like, including widgets and connections to social media platforms). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum through any of our Services may be viewed and used by others without any restrictions or notifications or compensation to you. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes. Always use social media with an understanding your data may be seen, replicated, shared and distributed for the world to see.
Where We Store Your Personal Data
Data Storage: All data that you provide to use through our Services is transferred or stored on the cloud through servers we pay for from popular providers. Any payment transactions will be encrypted using SSL technology; all payment data is stored by our payment processors and is never stored on our servers. Where we have given you (or where you have chosen) a password that enables you to access your account and the Services, you are responsible for keeping this password confidential. We recommend that you not share your password and that you change it frequently.
Data Security: Lions Guide takes reasonable measures to protect your personal information and your content from loss, misuse, and unauthorized access, disclosure, modification, and destruction and to ensure that your content remains protected and available to you. Unfortunately, the transmission of data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted through the Services or any device. All use and transmissions are at your own risk. You alone are responsible for your account and data shared with others, so to protect your user account, we encourage you to:
- use a strong password that is unique to your Luke Harlan Coaching account
- never share your password with anyone
- limit access to your phone, computer and browser
- log out once you have finished using Luke Harlan Coaching on a shared device
It's your responsibility to only provide individuals with permission to use your account where you're comfortable sharing this personal data with them. Please remember that if other people have access to your account, then they can access your personal data and app controls and that it may impact your personalized recommendations and be included in your data.
Data Retention: Luke Harlan Coaching stores the information we collect for as long as necessary for the purpose for which it was originally collected and in compliance with our legal obligations. The retention periods applied by Luke Harlan Coaching comply with applicable legislation then in effect, namely:
- For data relating to your account, such data will not be retained beyond your request that your account be entirely deleted. We do keep some of your data if you unsubscribe or cancel, so that if you wish to purchase again later your account or information (like your journal entries or scores) is available to you.
- For transactional data relating to your purchases, such data is kept for the entire period of our contractual relationship, then in accordance with legal obligations and applicable statute of limitations periods. Please note that this data does not include payment card information, which is processed by our third-party payment processors and not Luke Harlan Coaching.
- For data collected based on your consent to receive marketing communications, we will use the data until you withdraw your consent or applicable law requires that such data is no longer used.
- For data collected in connection with your requests or questions, such data is kept for the period necessary to process and reply to your request or question.
- When cookies or other trackers are placed on your computer, they may be retained for a period of 12 months.
We may retain certain information for legitimate business purposes or as required by law.
Children Age 13 and Under
Luke Harlan Coaching’s Services is not marketed to or directed at children under the age of 13 and we do not knowingly collect personal information from children. We recognize the special obligation to protect personally identifiable information obtained from children and we may seek to identify or remove accounts or information from children under the age of 13.
Luke Harlan Coaching encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:
- Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
- Know the sites your kids are visiting and which sites are appropriate.
- Look for Website privacy policies. Know how your child’s information is treated.
- Check out the FTC’s site for more tips on protecting children's privacy online.
If you're a parent or legal guardian of a child who is under 13 (or an age limit determined in a specific country as relevant) who has provided personal data to Luke Harlan Coaching, please contact us. We'll take reasonable steps to investigate or delete the personal data or account of the child.
How We Use “Cookies” and Other Tracking Technologies
You have a choice about the placement of cookies on our website. You can use your web browser to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation. Guidance on how to control cookies in popular browsers is contained here:
- What are cookies and pixels? A cookie is a small text file stored on a user’s device that may later be retrieved by a web server from the device. Cookies allow web servers to do certain things like remember the items you placed in a shopping cart or that you are logged in. Some cookies let us and service providers keep track of our website users’ browsing activities and connect certain activities into a session. A pixel is a very small image that may be found within web pages and emails that requires a call to our servers in order for the pixel to be rendered in those web pages and emails—this call provides information about your device and visit. We use pixels to learn more about your interactions with email content or web content, such as whether you interacted with ads or posts. Pixels can also enable us and third parties to place cookies on your browser.
- Are there different types of cookies? Cookies typically are classified as either session cookies or persistent cookies. Session cookies disappear from your device or browser when you turn off your device. Persistent cookies remain on your browser even if you turn off your device. We use both persistent cookies and session cookies.
- Can you stop us from setting cookies? Yes, you can prevent a website, including ours, from setting cookies. However, if you do so, some parts of the website may not function properly or at all.
Your Choices and Rights
You have several options with respect to your personal information, as follows:
- You may terminate your use of the Services at any time. However, please note that Luke Harlan Coaching may still process your personal information as a service provider to our customers if your personal data.
- If you have created an account, you may at any time access, edit, or delete your personal information. Please note that even if you delete information from your account, or deactivate your account, we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your information for a certain period of time.
- You may opt out of receiving promotional emails, text messages, or mail from Lions Guide by writing us at [email protected], or where applicable visiting your user settings or preferences in our app or sites, or clicking “Unsubscribe” link in any promotional email. If you opt out, we may still send you transactional or relationship messages, such as emails about your account or updates to our Services.
- If you do not have a user account and wish to delete your email address or other personal information that you might have provided through your use of our Services and/or any other services, please email us at: [email protected] with the words “Delete My Information” in the subject line.
We do not knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.
Links to External Sites
Data Posted in App or on Forums
Luke Harlan Coaching users may have the ability to post content to one or more Luke Harlan Coaching forums, such as chat rooms, community sites, group calls or video, comments in apps or sites, and online bulletin boards. You should be aware that when you voluntarily disclose personal information in any forum, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances, as it is public and can be used by others including Luke Harlan Coaching at our discretion. Please take care when using these features. You may request and obtain removal of such posted content by contacting us at [email protected] and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the Luke Harlan Coaching forums.
Transfer of Information Across National Borders:
For users located outside the jurisdiction of the United States, Luke Harlan Coaching operates and processes data in the United States. Information we collect from you will be processed in the United States, and by using this website you acknowledge and consent to the processing of your data in the United States. The United States has not received a finding of “adequacy” from the European Union under Article 41 of the GDPR. We collect and transfer to the U.S. personal data only with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. When we transfer your personal information to other countries, we will protect that data as described in this Policy or in our agreement with you and take steps, where necessary, to ensure that international transfers comply with applicable laws.
Your California Privacy Rights:
Please review the “California Supplemental Privacy Notice” which is incorporated as part of this Policy for California residents only.
Residents of the European Economic Area
We provide the representations and information in this section in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). If you are a visitor from the European Territories (including the European Economic Area, Switzerland, and the United Kingdom), our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal data from you where the processing is in our legitimate interests. In some cases we may collect, and process personal data based on consent.
EU data subjects have certain rights with respect to your personal data that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
- Access, Correction or Deletion. You may request access to, correction of, or deletion of your personal data. You can often go directly into the Service under Account Settings to take these actions.
- Objection. You may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes and may do so using the options provided in this Policy. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Restriction. You have the right to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Portability. You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent. If we have collected and processed your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal data. To file a request or act on one of your rights, please contact us at the contact details provided below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
General Data Protection Regulation (GDPR) - European Representative: Pursuant to Article 27 of the General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as its GDPR representative in the European Economic Area. You can contact EDPO regarding matters pertaining to the GDPR by:
- Sending an email to [email protected]
- Using EDPO’s online request form at https://www.edpo.brussels/contact
- Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
If you are a resident of the European Economic Area and have a data privacy concern that we are unable to resolve, you have the right to file a complaint/inquiry with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
UK General Data Protection Regulation (GDPR) – UK Representative: Pursuant to the UK GDPR, Lions Guide has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
- Using EDPO UK’s online request form: https://edpo.com/uk-gdpr-data-request/
- Writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
Do Not Track Disclosure
Regulatory agencies such as the U.S. Federal Trade Commission have promoted the concept of Do Not Track as a mechanism to permit Internet users to control online tracking activity across websites through their browser settings. Since no industry standard has been adopted, we currently do not process or comply with any web browser’s “do-not-track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit the Luke Harlan Coaching website or use our Services.
Contact Information for Complaints or Concerns
Your Acceptance of These Terms