Last Updated: July 2018
Information we collect
Information you submit to us
You may choose to provide personal information (for example, your name, address, e-mail address, telephone number) on our Website for various purposes, including the following.
- News, Alerts, and Publications: On our Website, you may sign up to receive, news, alerts, and publications from Empowerment Partnership or its affiliate, NLP.com. To sign up, you will be asked to provide information such as your name, and email address. We use this information to send you the communications you requested. We also may use this information to communicate with you about other topics we believe may be of interest to you, where we have a legitimate basis for doing so.
- Contact Us: You can communicate with us through the “Contact Us” link on our Website, which will ask you to provide your name, postal code or zip code, phone number, and email in connection with the comment or question you submit to us. We use this information to communicate with you about your comments or questions. We may also use the information you provide to communicate with you about topics we believe may be of interest to you.
- Other site features: Our Website offers various features that may change from time to time. We may provide you with an opportunity to submit certain personal information so we can provide you with and communicate with you about these features based on our legitimate interest in providing you with useful features.
- Other uses of information: We may use the personal information you provide on the Website for our internal purposes. These purposes include administration of the Website, market research, data analytics, and compliance with our legal obligations, policies, and procedures.
We may collect other information about you that does not reveal your specific identity or does not directly relate to an identifiable individual, such as: (1) browser and device information; (2) information collected through cookies, pixel tags (also known as web beacons and clear GIFs), and other technologies; (3) demographic information; and (4) information that has been aggregated in a manner that it no longer reveals your specific identity (collectively, “Other Information”).
If we are required to treat Other Information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information as detailed in this Policy.
We use “cookies” on the website. A cookie is a small data file that the website writes to your hard drive when you visit. A cookie file can collection information such as your IP address, browser type, referring and exit pages, operating system, and dates/times of page views. A cookie cannot read data off your hard disk or read cookie files created by other sites.
A session ID cookie expires when you close your browser. We use session cookies to make it easier for you to navigate the Website. A persistent cookie remains on your hard drive for an extended period of time. We use persistent cookies to recall what information you have viewed in prior visits to the Website. You can remove persistent cookies by following directions provided through your Internet browser.
The Website uses these cookies:
First Party Cookies
We do not currently respond to browser do-not-track signals.
Our Website is directed at individuals over the age of 18 and is not directed at children under the age of 13. We will not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, do not provide personally identifiable information of any kind. Should you suspect that a child of whom you are the parent or legal guardian has provided us with personal information, please contact us at firstname.lastname@example.org and we will work with you to address the issue.
Your California Privacy Rights
Under California Civil Code Section 1798.83, California users are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. We may disclose your personal information to NLP.com. We are providing the following information for California residents who have provided us with their personal information during the creation of or during the course of an established business relationship that is primarily for personal, family, or household purposes (“Individual California Users”).
Individual California Users must submit their requests to use either by email at email@example.com and/or by mail at P.O. Box 2260, Honolulu, HI 96803.
We will provide a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the firstname.lastname@example.org or mailing address, P.O. Bo 2260, Honolulu, HI 96803, specified in this section.
How we use your information
We use your personal information for legitimate business purposes, including:
- Providing the functionality of the Website and fulfilling your requests:
- To maintain the functionality of the Website.
- To respond to your inquiries and fulfill your requests when you contact us via one of our online contact forms.
- To send administrative information to you, such as information regarding our services and changes to our terms, conditions, and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials
- To send you our newsletters, publications, and mailings related to our seminars or events that we think might be of interest to you.
- To send you information about our services and other news about Empowerment Partnership or NLP.com
We will engage in this activity with your consent or where we have a legitimate interest.
- Aggregating and/or anonymizing personal Information
- We may combine your personal information with that of all or a particular group of Website users to prepare collective and anonymous profiles of site users and their interests or behaviors.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of the services we provide to our customers or to enhance, improve, or modify our current products and services.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
- For fraud and security monitoring purposes, e.g., to detect and prevent cyberattacks or attempts to commit identity theft.
- To meet our legal and regulatory obligations.
- For identifying usage trends, for example, understanding which parts of our services are of most interest to users.
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
We engage in these activities with your consent, to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
If we contact you using your personal information, it will be in the following ways:
Email: We only send emails to site visitors and users who sign up for one of our mailing lists or who agree to receive future communications from us. Our emails to you will contain clear information on how to unsubscribe from future communications. If you sign up for communications from us but then wish to unsubscribe, follow the unsubscribe instructions in the email you receive from us. Once we receive your unsubscribe request, we will cease our communication with you until and unless you re-subscribe for one of our mailing lists. You may also choose to stop receiving emails from us by notifying us at email@example.com at anytime. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
Postal mail: We may also send you communications via postal mail. If you are receiving postal mail communications from us and wish to no longer receive them, please email us at [email address] to ask us to remove you from our postal mailing list.
Telephone: We may also contact you by phone where you provide your phone number, in connection with the service request, comment, or inquiry you submit to us via the Website. If you do not wish to be contacted by phone, please indicate that to the individual who is calling you on our behalf, and we will remove your phone number from our contact list.
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide services to you;
- The length of time we have an ongoing relationship with you as our client and provide you with services;
- Whether we are subject to a legal obligation to retain records (e.g., certain laws require us to keep records of your transactions or communications for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (e.g., in regard to applicable statutes of limitations, litigation or regulatory investigations).
Information we transfer or share with others
Consent: We may share information you submit to us with your consent or at your direction
Service providers: We may share your information with service providers we have retained to perform services on our behalf, for example, to host our Website or send email communications. We obligate these service providers to not use or disclose the information they receive from us except as necessary to perform services on our behalf or to comply with legal requirements.
Compliance with law: In addition, we may disclose information about you (i) if we are required to do so by law; (ii) in response to a request from law enforcement authorities or other government officials; (iii) in connection with a judicial proceeding or to comply with a court order, law, or regulation applicable to us or the Website; or (iv) when we believe disclosure is necessary or appropriate to protect our property or assert our legal rights or to protect the property or safety of any other person.
Sale or business transaction: We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
Marketing choice and your rights to access and correct your personal information
We want to make sure that your personal information is accurate and up to date. You have the right to request access to and correction or deletion of your personal data, restrict processing concerning you and object to processing, as well as the right to data portability.
We will provide you with access to your personal information on request so you may view, update or correct your information. To protect your privacy and security, we will verify your identity before granting you access or enabling you to make corrections. You have the right to complain to a competent supervisory authority if you feel that we are not complying with our data protection obligations.
If you would like to access or correct your personal information or preferences, or have your information removed from our mailing list, please notify us at firstname.lastname@example.org.
How we protect personal personal information
To prevent unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and to ensure the correct use of information, we employ physical, technical, and administrative safeguards to protect against unauthorized disclosure, access to, or loss of the personal information we collect through the Website. All of our employees and any third parties we employ to process your personal information are obliged to respect its confidentiality. However, transmission of information through the internet is not secure. Although we seek to protect your information as described above, we cannot guarantee the security of any information you transmit to the Website or to us, and you transmit such information at your own risk.
How to contact us