This policy describes the Company’s practices for collecting, using, maintaining, protecting, and disclosing the personal data it may collect from you or that you may provide when you visit any Diabetesfreedom.org Program website (collectively, the “Website”) and the Company’s practices for collecting, using, keeping, protecting, and disclosing that information.
This policy applies to the personal data collected through the Website, regardless of the country where you are located.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you.
- Data the Company may collect about you Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). The Company may collect, use, store, and transfer different kinds of personal data about you, which the Company has grouped together as follows:
Identity Data includes first name and last name.
Contact Data includes billing address, delivery address, email address, and telephone numbers.
Financial Data includes payment card details.
Transaction Data includes details about payments from you and other details of products you have purchased from the Company.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
Profile Data includes your purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use the Company’s Website, products, and services.
Marketing and Communications Data includes your preferences in receiving marketing from the Company and its third parties and your communication preferences.
The Company also collects, uses, and shares Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, the Company may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if the Company combines or connects Aggregated Data with your personal data so that it can directly or indirectly identify you, the Company treats the combined data as personal data which will be used in accordance with this policy.
The Company does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor does the Company collect any information about criminal convictions and offenses.
If you fail to provide personal data
Where the Company needs to collect personal data by law or under the terms of a contract it has with you and you fail to provide that data when requested, the Company may not be able to perform the contract it has or is trying to enter into with you (for example, to provide you with goods or services). In this case, the Company may have to cancel a product or service you have with the Company, but the Company will notify you if this is the case at the time.
- How the Company collects data about you
The Company uses different methods to collect data from and about you including through:
Direct interactions. You may give the Company data about you by filling in forms or by corresponding with the Company by phone, email, or otherwise. This includes personal data you provide when place an order; review a product; request marketing to be sent to you; request information about the Company’s products; enter a competition, promotion, or survey; give the Company feedback; and when you report a problem with the Website.
Automated technologies or interactions. As you interact with the Website, the Company may automatically collect technical data about your equipment, browsing actions, and patterns as specified above. The Company collects this data by using cookies, server logs, and other similar technologies.
Third parties or publicly available sources. The Company may receive data about you if you visit other websites employing the Company’s cookies or from third parties including, for example, business partners (including affiliates in the Website’s affiliate marketing program); subcontractors in technical, payment, and delivery services; advertising networks; analytics providers; and search information providers.
Cookies and automatic data collection technologies
Estimate the Website’s audience size and usage patterns.
Store your preferences so the Company may customize the Website according to your individual interests.
Speed up your searches.
Recognize you when you return to the Website.
The Company does not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
- How the Company uses your personal data
The Company uses your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how the Company may use the personal data it collects includes to:
Present the Website and provide you with the information, products, services, and support that you request from the Company.
Meet the Company’s obligations and enforce its rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
Fulfill any orders placed through the Website (including processing your payment information, arranging for shipping, and providing you with invoices or order confirmations).
Communicate with you.
Screen orders for potential risk or fraud.
Fulfill the purposes for which you provided the data or that were described when it was collected.
Notify you about changes to the Website, products, or services.
Ensure that the Company presents the Website content in the most effective manner for you and for your computer.
Administer the Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
Improve the Website, products or services, marketing, or customer relationships and experiences.
Enable your participation in the Website’s interactive, social media, or other similar features.
Protect the Website, the Company’s employees, or the Company’s operations.
Measure or understand the effectiveness of the advertising the Company serves to you and others, and to deliver relevant advertising to you.
Make suggestions and recommendations to you and other users of the Website about goods or services that may interest you or them.
The Company may also use personal data to contact you about its own and third parties’ goods and services that may be of interest to you via email, direct mail, or otherwise. For more information, see Your personal data use choices.
The Company may use personal data to enable it to display advertisements to its advertisers’ target audiences. Even though the Company does not disclose your personal data 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. If you are an European Economic Area (EEA) resident, please note that the Company is processing your data to fulfill contracts it might have with you (for example, if you make an order through the Website), to comply with a legal obligation, or otherwise to pursue its legitimate business interests, more specifically its economic interest in offering you products and services, growing its business, making you personalized offers, and in recovering any debts due to it. The Company may use nonpersonal data for any business purpose.
- Disclosure of your personal data
The Company may share your personal data with:
Any member of the Company’s corporate group, which means its subsidiaries, its ultimate holding company and its subsidiaries, and affiliates.
Business partners, suppliers, service providers, subcontractors, and other third parties that the Company uses to support its business (such as analytics and search engine providers that assist the Company with Website improvement and optimization). For example, the Company uses ClickBank to power its online store (you can read more about how ClickBank uses your personal data here: https://support.clickbank.com/hc/en-us/articles/360004023572-Customer-Privacy-Policy). The Company also uses Google Analytics to help the Company understand how its customers use the Website (you can read more about how Google uses your personal data here:https://www.google.com/int’l/en/policies/privacy/). You can also optout of Google Analytics here:https://tools.google.com/dlpage/gaoptout
The Company contractually requires these third parties to keep that personal data confidential and use it only for the contracted purposes.
Third parties such as third-party publishers and advertisers to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes. For more information, see Your personal data use choices.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
The Company may also disclose your personal data to third parties:
If the Company sells or buys any business or assets, in which case the Company may disclose your personal data to the prospective seller or buyer of the business or assets.
To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data the Company holds.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply the Company’s Terms-of-Use Agreement, Terms-of-Sale Agreement, and other agreements.
To protect the rights, property, or safety of the Company’s business, its employees, its customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
To fulfill the purpose for which you provide it.
For any other purposes that the Company discloses when you provide the data.
With your consent.
The Company may share nonpersonal data without restriction.
- Cross-border data transfers
The Company is based in the United States. For operational reasons the Company may process, store, and transfer personal data it collects, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where the Company does so, and where the Company is required to under local law, the Company will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed.
If you are located outside the United States, the Company advises you that your personal data may at times be accessible by persons who are located worldwide including in countries that the European Commission or other geopolitical regions have not determined to provide the same adequate level of data protections in your country, province territory, or geopolitical region. By submitting your personal data or engaging with the Website, you consent to the Company’s transfer, storing, or processing, including the transfer of your data across international boundaries to jurisdictions anywhere in the world as permitted by local law.
If you are a European Economic Area (EEA) or Switzerland resident or otherwise located in the EEA or Switzerland, please note that your information will be transferred outside of the EEA or Switzerland, including to the United States. If you are a Canadian resident or otherwise located in Canada, please note that personal data transfers outside of Canada may result in your data becoming accessible to foreign jurisdiction’s law enforcement or other authorities.
- Your personal data use choices
The Company strives to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. The Company has established the following personal data control mechanisms:
Promotional offers from the Company. If you do not want the Company to use your Contact Data to promote its own products and services, or third parties’ products or services, you can opt out by sending the Company an email with your request to support @ trbsystem-us.us . You may also opt out of further marketing communications by replying to any promotional email the Company has sent you or following the opt out links on that message. This opt out does not apply to information provided to the Company as a result of a product purchase, product service experience, or other transactions.
Third-Party Advertising. If you do not want the Company to share your personal data with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending the Company an email stating your request to support @ trbsystem-us.us
Targeted Advertising. If you do not want the Company to use data that it collects or that you provide to the Company to deliver advertisements according to its advertisers’ target-audience preferences, you can opt out by sending the Company an email stating your request to support @ trbsystem-us.us. For this opt out to function, you must have your browser set to accept browser cookies.
The Website may, from time to time, contain links to and from the websites of the Company’s partner networks, advertisers and affiliates, or plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that the Company does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.
- Accessing and correcting your personal data
You may send the Company an email at support @ trbsystem-us.us to request access to, correct, or delete any personal data that you have provided to the Company. The Company may not accommodate a request to change data if the Company believes the change would violate any law or legal requirement or negatively affect the data’s accuracy.
- Data security
The security of your personal data is very important to the Company. The Company uses reasonable and appropriate security measures designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. The Company stores all personal data behind firewalls on severs employing security protections. The Company encrypts any payment transactions using SSL technology. The safety and security of your information also depends on you. Where the Company has given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. The Company asks you not to share your password with anyone. The Company urges you to take care when providing information in public areas of the Website, which any Website visitor can view. Unfortunately, the transmission of information via the Internet is not completely secure. Although the Company does its best to protect your personal data, the Company cannot guarantee the security of your personal data transmitted to the Website. Any transmission of personal data is at your own risk. The Company is not responsible for the circumvention of any privacy settings or security measures contained on the Website.
- Date retention How long will the Company use my personal data for?
The Company will only retain your personal data for as long as reasonably necessary to fulfill the purposes it collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. The Company may retain your personal data for a longer period in the event of a complaint or if the Company reasonably believes there is a prospect of litigation in respect to its relationship with you. To determine the appropriate retention period for personal data, the Company considers the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which the Company processes your personal data and whether it can achieve those purposes through other means; and the applicable legal, regulatory, tax, accounting, or other requirements. By law the Company has to keep basic information about its customers (including Contact, Identity, Financial, and Transaction Data) for seven years after they stop being customers or affiliates for tax purposes. In some circumstances you can ask the Company to delete your data: see
Accessing and correcting your personal data
In some circumstances the Company will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case the Company may use this information indefinitely without further notice to you.
- Children’s online privacy
The Company does not direct its Website to minors and it does not knowingly collect personal data from individuals under 18-years old. If the Company learns it has mistakenly or unintentionally collected or received personal data from an individual under 18-years old, it will delete it. If you believe the Company mistakenly or unintentionally collected data from or about an individual under 18-years old, please contact the Company at firstname.lastname@example.org.
- Do Not Track policy
Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. The Company is committed to providing you with meaningful choices about the information it collects and that is why the Company provides you the ability to opt out. But the Company does not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.
- Your California privacy rights
If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by the Company to third parties for the third parties’ direct marketing purposes. Further, if you are a California resident and would like to opt out from the disclosure of your personal data to any third party for direct marketing purposes, please send an email to support @ trbsystem-us.us. If you opt out from permitting your personal data to be shared, you may still receive selected offers directly from the Company in accordance with California law.
- Your EU GDPR and Swiss privacy rights
If you reside in the European Economic Area (EEA) or Switzerland, under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights may include the following:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data the Company holds about you and to check that the Company is lawfully processing it.
Request correction of the personal data that the Company holds about you. This enables you to have any incomplete or inaccurate data the Company holds about you corrected, though the Company may need to verify the accuracy of the new data you provide to the Company.
Request erasure of your personal data. This enables you to ask the Company to delete or remove personal data where there is no good reason for the Company continuing to process it. You also have the right to ask the Company to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where the Company may have processed your information unlawfully, or where the Company is required to erase your personal data to comply with local law. Note, however, that the Company may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where the Company is 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 the Company is processing your personal data for direct marketing purposes. In some cases, the Company may demonstrate that it has compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data. This enables you to ask the Company to suspend the processing of your personal data in the following scenarios: (a) if you want the Company to establish the data’s accuracy; (b) where the Company’s use of the data is unlawful but you do not want the Company to erase it; (c) where you need the Company to hold the data even if the Company no longer requires it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to the Company’s use of your data but the Company needs to verify whether it has overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. The Company 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 the Company to use or where the Company used the information to perform a contract with you.
Withdraw consent at any time where the Company is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, the Company may not be able to provide certain products or services to you. The Company will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact the Company at support @ trbsystem-us.us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, the Company may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, the Company may refuse to comply with your request in these circumstances.
The Company may need to request specific information from you to help it confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. The Company may also contact you to ask you for further information in relation to your request to speed up its response. The Company tries to respond to all legitimate requests within one month. Occasionally it may take the Company longer than a month if your request is particularly complex or you have made a number of requests. In this case, the Company will notify you and keep you updated.
- Contact Information
Questions, comments, requests, and complaints regarding this policy or the Company’s privacy practices are welcomed and should be addressed to trbsystem-us.us.