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Student Blog

Assuaged Privacy Policy

UPDATED 08-04-2023

At Assuaged Foundation, Inc., and Assuaged, Inc., dba Be Your Highest, we are committed to protecting your privacy. This Privacy Policy applies to our Websites (assuaged.com) and (beyourhighest.com) and (beyourhighest.org) and (assuagedmarketing.com) and Subscription Service and governs our data collection, processing, and usage practices. By using our Website and Subscription Service, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in things Privacy Policy, you should not use our Website or Subscription Service.

Note: We periodically update this Privacy Policy, so please occasionally check back for any revisions. If you have any questions regarding this policy, please don't hesitate to contact us.

1. Privacy Policy for our websites, iOS mobile app, products and services


Elements of our Privacy Policy include the following:

  • The categories of personally identifiable information (“PII“) we collect.
  • How we disclose your information.
  • How you can change your information.
  • What type of security we use to protect your information.
  • How we may change this Privacy Policy.

By submitting PII through our Websites, you agree to the terms of this Privacy Policy, and you expressly consent to the processing of this PII by our Privacy Policy.

This Privacy Policy also describes how Assuaged, Inc., dba Be Your Highest (the “Sites” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Sites.

We use Hubspot to power our online consumer-facing educational platform and 501(c)(3) (assuaged.com), where students create engaging and educational content for public populations. You can read more about how Hubspot uses your Personal Information here: https://legal.hubspot.com/privacy-policy

We use Shopify to power our online store (beyourhighest.com) and our secondary 501c3 non-profit organization affiliated student marketing agency (assuagedmarketing.com). You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.

We use GoDaddy to power our secondary online student-appropriate store (beyourhighest.org) as a helpful revenue stream to help fund our 501c3 non-profit organization Assuaged Foundation. You can read more about how GoDaddy uses your Personal Information here: https://www.godaddy.com/agreements/privacy.

Who We Are. The Assuaged websites and its services, including the Mobile App and Missions, is owned by Assuaged Foundation, Inc., and Assuaged, Inc., dba Be Your Highest Information collected by Assuaged’s websites, app, email contact, or other methods of communication are all collected by Assuaged, Inc.

A Note About Children. We do not intentionally gather PII about visitors who are under the age of 16 unless they apply for our High School Internship program given parental consent. Our high-school internship program is limited as we only accept two students yearly. Our Websites and Subscription Service are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us so that we may permanently delete the information.

Safeguarding students and their personal information:

Assuaged Foundation firmly believes that the personally identifiable information of children and students warrants special protection, and as such, we adhere to the Children’s Online Privacy Protection Act (“COPPA”) and The General Data Protection Regulation (“GDPR”). We also assist educational institutions in fulfilling their obligations under the Family Educational Rights Privacy Act (“FERPA”).

Assuaged Foundation provides a selective set of features and website experiences for young users. We do not require students to provide their name or contact information, nor do we mandate them to create accounts. When a student indicates that they are below the age where they can provide consent independently, Assuaged Foundation does not collect personal information as defined under COPPA, and may implement additional measures to protect student privacy as mandated by law. Aside from what is detailed in this privacy policy, Assuaged Foundation does not gather personal information about any child for distribution, sharing, or selling.

A Note To Users Outside Of The United States. Your PII may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of PII may be less stringent than the laws in your country.

2. COLLECTION OF YOUR INFORMATION


By Assuaged Foundation, Inc., and Assuaged, Inc., dba Be Your Highest. If you contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, to send you a reply. When you post messages on the bulletin board, chat room, blog or forum of our Websites, the information contained in your posting will be stored on our service provider’s servers.

By Cookies. A cookie is a small text file stored on a user’s computer for record-keeping purposes such as site visitation. We use cookies on our Websites. We do not link the information we store in cookies to any PII you submit while on our Websites. If you choose to disable cookies, some areas of our Websites may not work properly.

By Disclosure for a business purpose: shared with our processor Shopify.

While you don't need to provide any information in order to explore and enjoy our Websites, we do collect Navigational Information.

In addition, we sometimes request that you provide Personal Information when you're seeking certain things from us (like our downloadable eBooks or guides, for example).

"Navigational Information" refers to information about your computer and your visits to our websites, such as your IP address, geographical location, browser type, referral source, length of visit, and pages viewed.

"Personal Information" refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, email address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into via our Websites, and information about you that is publicly available on the Internet, such as from Facebook, LinkedIn, Twitter, Instagram and Google, or publicly available information that we acquire from service providers.

3. DISCLOSURE OF YOUR INFORMATION


Aggregate Information (non-personally identifiable). We share aggregated demographic and usage information about our Website users with our business partners, such as product data providers, food manufacturers, and retail stores. This information does not identify individual users. We do not link aggregate user data with PII.

Legal Disclaimer. We reserve the right to disclose your PII as required by law and when we believe that disclosure is necessary to protect our rights (or those of our Website users) and/or to comply with a judicial proceeding, court order, or legal process served on our Websites.

Disclosure to Third Party Service Providers. We may share your PII with our third party service providers to provide you with the Websites and Services. Except as otherwise stated in this Privacy Policy, these third party service providers are required not to use your PII other than to provide the services requested by Company. You expressly consent to the sharing of your PII with our service providers for the sole purpose of providing services to you.

Marketing. We do not share your PII with third parties for promotional purposes unless you have opted-in to such disclosure. If you have opted-in to have your PII shared, to opt-out from receiving further communications from any third party that is not our agent or service provider, please contact that marketing partner/affiliate directly. We will only contact you with promotional, product usage and customer service emails if you opt-in by providing us with your email address. When you receive such emails from us, you may indicate a preference to stop receiving further emails from us, and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive. Despite your indicated e-mail preferences, we may send you notices of any updates to our Terms of Service or Privacy Policy.

Links To Other Websites. If you click on a link to a third party site, you will leave the site you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your PII by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as Assuaged. We encourage you to review the Privacy Policies of any other service provider from whom you request services.

Bulletin Boards/Chat Rooms/Blogs/Forums. If you use a bulletin board, chat room, blog or forum on our Websites, you should be aware that any PII you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the PII you choose to submit in these forums.

Social Media (Features) and Widgets. Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

We never sell your personal information. Ever.

We will never sell your Personal Information to any third party. 

We use your personal information to make your web experience better.

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to improve your browsing experience by personalizing our Websites and to improve the Subscription Service with more targeted content.

If you choose to download something from our site (or some similar action), you will need to provide, at the very least, an email address. We will use this email address to deliver the item you've asked for or to provide further directions on how to obtain it. You may receive further communications from Assuaged Foundation, Inc., and Assuaged, Inc., dba Be Your Highest, that we deem relevant to your business. That said, you are always in control and can unsubscribe yourself from these communications at any time by clicking on the "unsubscribe" link at the bottom of every email or contacting us via phone, email, snail mail, or through our contact page.

At that point, we won't email you any further communications unless at some point you change your mind and you decide to provide your expressed consent. We do this because we strive to be in compliance with the United States' CAN-SPAM Act and the European Union's GDPR.

For (beyourhighest.com) your personal information will be processed in the USA. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

4. SPECIFIC PROCESSING BASIS

The legal grounds for gathering and utilizing the personal data delineated in this Privacy Notice depend on the specific personal data involved and the unique purposes for its collection.

We collect and utilize your information for several reasons, including those that (a) lie within our legitimate interests (for instance, providing educational programs, assessing your academic performance, undertaking admissions research, managing internal administrative tasks, executing analytics to enhance our websites or program offerings, and soliciting gifts or donations), (b) are essential in order to form or perform a contract with you (for instance, offering educational programs, processing your application for admission, processing your payments or donations, registering you for courses or events, and overseeing employment or other work relationships), (c) you have given consent to, or (d) are necessary to comply with our legal responsibilities (for instance, financial aid reporting, tax filing, and reporting of adverse incidents to regulatory bodies).

Processing the personal data of members of the Assuaged Foundation community is crucial for the legitimate interests pursued by the non-profit organization. This includes maintaining relationships with alumni and friends of the foundation, providing services to these alumni and friends, and presenting the student community with a customized opportunity to support the Assuaged Foundation in the specific ways that hold or may hold the most significance to the community.

If you desire to learn more about the specific legal grounds we rely on to process your information for any particular purpose (including any legitimate interests we have in processing this information), please feel free to contact us.

5. GDPR PRIVACY NOTICE

The European Union (“EU”) General Data Protection Regulation 2016/679 (the “GDPR”) regulates the protection of certain people with regard to the processing of their personal data and the free movement of such data. Before Assuaged Foundation, Inc. (“Foundation”) collects any personal data from you, we are required to provide certain information which is contained in this GDPR Privacy Notice (“Notice”).

I. Applicability and Definitions

This Notice applies to persons located in the EU, a European Economic Area (“EEA”) member state, Switzerland, or any country which formally adopts the GDPR (“GDPR Countries”). GDPR went into effect on May 25, 2018, and applies to the processing of personal data from and after that date. For the purpose of this Notice, the following definitions apply:

“Personal data” means any information that can be used to directly or indirectly identify you, such as your name, date of birth, addresses (including email addresses), identification numbers, location data, online identifiers, or factors specific to your physical, physiological, genetic, mental, economic, cultural, or social identity.

“Sensitive data” means personal data related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sex life or sexual orientation.

“Processing” and “Process” is any operation performed on your personal data, including collecting, storing, altering, transferring, sharing, disclosing, erasing, or destroying your data.

“Controller” means an entity that determines the purposes and means of processing personal data. The Foundation is a Controller within the meaning of the GDPR.

Terms in this Notice are intended to be used consistent with their definitions in the GDPR. The full text of the GDPR is available at https://gdpr-info.eu/.

II. The Type of Data Collected and the Foundation’s Purposes and Legal Bases to Process the Data

The Foundation processes your personal data for the purpose of furthering its charitable, health improvement and scientific missions and in connection with your relationship with the Foundation as a participant, member, donor, supporter, research subject, visitor to the Foundation or its website, or attendee at a Foundation event.

The categories of personal data we process about you may include the following:

- Identity data
- Contact data
- Background data
- Financial data
- Technical data
- Profile data
- Marketing and Communication data
- Sensitive data

The Foundation processes your personal data only when we have a legal basis to do so. Most commonly, it is necessary for the Foundation to process your personal data for the following legal bases recognized by the GDPR:

- To take steps to enter a contract with you, or to perform a contract to which you are a party.
- Where the Foundation or a third party has a legitimate interest, and your interests and fundamental rights do not override those interests.
- To protect the vital interests of health and safety of you or a third party.
- To comply with a legal or regulatory obligation.

When the Foundation cannot rely on any of these legal bases, or if it is necessary for the Foundation to process your sensitive personal data, it will seek your prior consent.

The purposes for which the Foundation collects your personal data, and the legal bases for processing such personal data, are summarized in the chart provided. Where the Foundation relies on a legitimate interest, it identifies the legitimate interests. The Foundation may have more than one legal basis to process your personal data depending on the specific purpose for which your personal data is used.

If you have additional questions regarding the type of personal data collected about you, or the Foundation’s purpose or legal basis for processing your personal data, please contact the Foundation at the contact provided below.

III. Other Recipients of Your Personal Data The Assuaged Foundation may share your personal data with other recipients in accordance with the purposes and lawful bases stated in Section II of this Notice. Categories of recipients who may receive your personal data may include the following: Foundation personnel involved in the activities outlined above. Public safety authorities, such as local, state, federal, or international law enforcement. Health care providers, such as hospitals and clinics. Security providers, such as private campus safety personnel. Regional and national accreditors and professional licensing bodies.

Third parties who underwrite, administer, or provide services related to the Foundation's programs or to individuals associated with the Foundation, such as independent contractors, marketing services, event hosting, international service providers, payment processors, insurance and benefits providers and administrators, lenders, and service providers who assist in scholarship and other financial aid programs.

Third parties to whom personal data is required to be communicated in order for the Foundation to comply with legal obligations established by any and all applicable laws and regulations, such as local, state, federal or international legal, governmental, and regulatory entities. Third-party data processors who host and/or process information on behalf of the Foundation. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. We require third parties to respect the security of your personal data and to treat it in accordance with applicable law.

IV. International Data Transfers Personal data that you provide while in GDPR Countries will be transferred internationally to the Foundation, which is located in the United States, and may be transferred to third parties in other countries in connection with the purposes and lawful bases stated in Section II of this Notice. In the international transfer of your personal data, the Foundation will employ suitable safeguards to protect the privacy and security of your personal data so that it is only used in a manner consistent with this Notice.

V. Data Security The Assuaged Foundation, by design, has put in place appropriate security measures to protect personal data from unauthorized access, alteration, disclosure, or destruction. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know, and who process your personal data at our direction. Where there is a personal data breach, we will notify you and any applicable regulatory authority where we are legally required to do so.

VI. Data Retention The Foundation retains your personal data for as long as necessary to fulfill the purposes for which we collected it. To determine the appropriate retention period for personal data, we consider the nature of the personal data, the purpose for which personal data is processed and retained, and the applicable legal, accounting, reporting, and regulatory requirements applicable to such data. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting the Foundation at the contact provided below. In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

VII. Your Rights Regarding Your Personal Data Under the GDPR, you have a number of rights regarding your personal data, subject to exceptions stated in the GDPR or its implementing regulations. Specifically, you have the right to: Request access to your personal data and receive a copy of the personal data that we hold about you. Request correction of your personal data that we hold which is inaccurate or incomplete. Request erasure of your personal data from our records. Where it is necessary for the Foundation to maintain the data for legal, accounting, reporting, or regulatory reasons, we may not be able to comply with your request and will notify you if that is the case.

Object to processing of your personal data where we are relying on a legitimate interest for processing such data, unless the Foundation can demonstrate compelling legitimate grounds for processing that override your interest in prohibiting such processing. Request restriction of processing your personal data under certain circumstances. Request the transfer (portability) of your personal data to a third party. Withdraw consent at any time where the Foundation relies solely on the legal basis of consent to process your personal data. If you withdraw consent, the withdrawal will not change the fact that your data has been processed legally up to that point. If you withdraw your consent, we may not be able to provide certain products or services to you.

We will advise you if this is the case at the time you withdraw your consent. File a complaint concerning your personal data with the applicable EU supervisory authority. Supervisory authority contact information is available here. Nearly all of your rights are qualified in various ways and there are numerous exemptions. For additional information about your rights, the full text of the GDPR is available at https://gdpr-info.eu/. If you wish to exercise any of these rights, please contact the Foundation at the contact provided below. The Foundation strives to respond to all legitimate requests within one month. It may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

VIII. Are You Obligated to Provide Personal Data? Through this Notice, the Foundation informs you that it may process your personal data in accordance with this Notice, and as permitted or required by law. If you do not agree with this Notice, please do not provide any personal data to the Foundation. If you choose not to provide personal data that is necessary for the Foundation to provide you with specific products or services, the Foundation may not be able to provide those products or services to you. For example, if you do not provide personal data needed to process applications, you will not receive the intended services or benefits from the Foundation.

IX. Contact Information and Rights Requests If you would like to contact the Assuaged Foundation in its capacity as a controller, including to ask questions about this Notice, the GDPR, and the personal data being processed by the Foundation, or if you wish to exercise any of your rights under the GDPR or lodge a complaint involving a violation of this Notice or the GDPR, please contact:

Assuaged Foundation
33271 Green Valley Lake Rd, # 8502
Green Valley Lake, CA 92341-0400
650-538-6633 | hello@assuaged.com

Please note that the Foundation is not a public authority or body. Also, its core activities do not include the regular and systematic monitoring of data subjects on a large scale, nor processing on a large scale of special categories of data or personal data relating to criminal convictions and offenses. For these reasons, the GDPR does not obligate the Foundation to designate a data protection officer within the meaning of the GDPR.

6. COMMUNICATIONS FROM THE SITE


Service-related Announcements. We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

Customer Service. Based upon the PII you provide us, we may send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email.

Updating Personally Identifiable Information. If your PII changes, or if you no longer desire our service, you may update or deactivate it by making the change on our member information page, by emailing our Customer Support at hello@assuaged.com, at the contact information listed below. We will respond to your request within 30 days.

7. DATA RETENTION


We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at hello@assuaged.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. SECURITY

The security of your PII is important to us. We follow accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.

9. CHANGES IN THIS PRIVACY POLICY


If we decide to change our privacy practices, we will post those changes to this Privacy Policy, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we change how we use your personally identifiable information, we will notify you here, by email, or through a notice on our home page. Any material changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Websites. These changes will be effective immediately for new users of our Websites.

10. CCPA COMPLIANCE

The CCPA applies to any for-profit entity doing business in California that collects and controls the processing of a consumer’s personal information and also satisfies ANY one of the following thresholds:

  • Exceeds $25 million gross revenue annually;
  • Handles the personal information of 50,000 or more California consumers, households, or devices annually; or
  • Derives more than 50% of annual revenue from selling consumers' personal information.

The CCPA also applies to any business that controls or is controlled by an entity that meets one of the above criteria and shares common branding with that entity. Non-profit organizations do not need to comply with the CCPA unless they are owned by, control, or share branding with a for-profit business.

Assuaged Foundation is a 501(c)(3) non-profit organization and we do not engage in any of thresholds mentioned nor do we ever share private information outside of our organization.

Assuaged, Inc., dba Be Your Highest is for profit, however, does not meet any of the above criteria.

11. PROCEDURE FOR COMPLAINTS REGARDING UNAUTHORIZED DATA DISCLOSURE/DATA BREACH

Parents, legal guardians, eligible students (students who are at least 18 years of age or attending a post-secondary institution at any age), principals, teachers, and employees of an educational agency may submit a complaint regarding a potential data breach or improper exposure of student data.

Investigations will be finalized in a reasonable time frame, usually within 60 calendar days from the receipt of the complaint. Should the investigation need to extend beyond 60 days due to extenuating circumstances, the complainant will be contacted to inform them of the delay and the anticipated timeline for completion.

Assuaged Foundation will keep a record of all complaints related to data breaches or unauthorized releases of student/staff data and their resolution in accordance with relevant data retention policies, and will report on complaint investigations and their outcomes.

We value the security of your personal information, but bear in mind that no method of transmission over the Internet or electronic storage method is 100% secure. While we aim to utilize commercially reasonable means to protect your personal information, we cannot guarantee the complete security of any information you transmit to our sites, and you do so at your own risk. Upon receiving your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please understand that this does not guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. While we endeavor to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online.

We encourage all individuals to utilize suitable safeguards to secure their computers and the information stored on them. For additional information on online privacy and security, please refer to Assuaged Foundation's policies and procedures related to Information Security; you may also consult with the California Attorney General’s Privacy Enforcement and Protection website.


In the event that personal information is compromised as a result of a security breach, we will promptly investigate and notify those individuals whose personal information has been compromised, in accordance with the notification procedures set out in the Assuaged Foundation Information Security Policy, or as otherwise required by applicable law.

12. THIRD PARTY LINKS

The Assuaged Foundation's websites may contain links to other websites or include content hosted and served by third parties that are not under the control of the Assuaged Foundation. These third parties, whose content appears on our websites, may collect information about you through the use of cookies and web beacons. They may also independently collect or solicit personal information and may have the ability to track your usage of their websites and services.

Similarly, our content, including some of our learning platforms, may be provided through or included on third parties' web pages and websites that are not associated with the Assuaged Foundation and over which we have no control. We may collect usage information through Assuaged Foundation content appearing on third-party sites. The Assuaged Foundation is not responsible for the privacy practices of any third party.

13. AUTOMATED DECISION-MAKING AND PROFILING

We may utilize the information you provide to us, in conjunction with the information we obtain from other sources, to better understand your interests. This enables us to anticipate and predict other products, services, and information that may be of interest to you. This practice, known as "profiling," involves making automated decisions about you based on this information. The aim of profiling is to better customize our interactions with you, making them more relevant and engaging. You can object to such profiling at any time by reaching out to us (refer to Contact Information/User Rights section below).

User Rights and Data Protection Officer
Your rights concerning your Personal Data are subject to the local laws within the jurisdiction where you live.

If you reside in the European Economic Area (EEA) or the United Kingdom (UK), you might have certain rights concerning your Personal Data under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, as outlined below:
- The right to be informed of the use of your Personal Data
- The right to access and/or require the correction or erasure of your Personal Data
- The right to block and/or object to the processing of your Personal Data
- The right not to be subjected to any decision based solely on automated processing of your Personal Data
- Under limited circumstances, you may have the right to receive Personal Data in a format which can be transmitted to another entity.

If you have a complaint regarding the processing of your data carried out under this Privacy Policy, you have the right to lodge a complaint with your local supervisory authority. If you are located in the European Union, you can find the details of your local supervisory authority here.

14. PINTEREST TAG

The “Pinterest Tag” (individual code segment) from Pinterest Inc., 33271 Green Valley Lake Rd, # 8502 Green Valley Lake, CA, USA, (“Pinterest”) is embedded on our websites.

Using the Pinterest tag, Pinterest is able to identify the visitors to our websites as a target group for displaying ads (“Pinterest ads”). Accordingly, we use the Pinterest tag so that our targeted Pinterest ads will only be displayed to Pinterest users who have actually shown an interest in our websites or who meet specific criteria (e.g. interest in specific topics or products that are determined based on the websites visited) which we indicate to Pinterest (known as “ActAlike Audiences”). Using the Pinterest tag, we also aim to ensure that our Pinterest ads match the potential interest of users and are not bothersome. In addition, we can also use the Pinterest tag to trace the efficacy of Pinterest ads for statistical and marketing purposes by seeing whether users were forwarded to our websites after clicking on a Pinterest ad (known as “Conversion”).

The Pinterest tag will only be activated if you have granted us your voluntary consent (in accordance with Art. 6 (1) a GDPR) in our request under cookie settings. You may withdraw or modify your selection there at any time with future effect (see Section 3).

All data that is collected remains anonymous to us and does not allow us to draw conclusions about the identity of the user in question. Data is collected concerning device information (e.g. type, brand), the operating system used, the IP address of the device used, the time of access, the type and content of the campaign, the reaction to the respective campaign (e.g. completed purchase, newsletter subscription) as well as device identifiers that consist of individual features of the end device. This enables us to recognize your end device on our websites.

If you log in to your Pinterest account after visiting our websites or if you visit our websites while logged in, this data may be stored and processed by Pinterest. Pinterest may potentially connect this data with your Pinterest account and also use it for their own marketing purposes. Further information can be found in Pinterest’s privacy policy: policy.pinterest.com/de/privacy-policy. You can object to this specific data processing at any time by deactivating the relevant settings in your Pinterest account help.pinterest.com/en/article/personalization-and-data at any time under “Personalization” or make adjustments to the cookie settings.

15. NEWSLETTER

The information below provides details about the content of our newsletter. It also explains our subscription and mailing procedures, the methods we use for performing statistical analysis and your rights to object. When you subscribe to our newsletter, you are consenting to receive the newsletter and to the procedures described.

Content of the newsletter

We only send the newsletter to recipients who have provided their consent in accordance with Article 6 (1) a GDPR or when it is legally permissible to do so. If, in relation to a subscription to the newsletter, the content of the newsletter is described in specific terms, this will serve as an essential basis for the user providing consent. Our newsletter contains information about our offers and promotions as well as about our company. It may also include information that specifically refers to blog posts, our services, or our online presence.

Using the mailing service provider “Hubspot”

We have commissioned Hubspot as a third-party service provider to distribute and analyze our newsletter. Furthermore, we use an online subscription service through HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA. To understand how HubSpot's subscription service works, we're quoting directly from HubSpot's privacy page regarding this matter:

"Our online Subscription Service allows any company that uses it (our customers and HubSpot itself) to create and share marketing, sales and customer service content. The Subscription Service can also be used to help organize sales data about a company’s sales pipeline (e.g., leads, customers, deals, etc.). The information added to the Subscription Service, either by site visitors providing their contact information or when a Subscription Service user adds the information, is stored and managed on our service providers' servers. This information is then used to contact visitors about their interest in the company's goods or services and interact with the company. HubSpot provides the Subscription Service to our customers for their own marketing, lead generation, and customer service needs, and we use it to meet HubSpot’s related needs." – HubSpot privacy policy, Feb 2022

HubSpot's agreement with Assuaged Foundation, Inc., and Assuaged, Inc., dba Be Your Highest, prohibits us from using the Subscription Service to collect, manage, or process Sensitive Information. "Sensitive Information" refers to credit or debit card numbers, personal financial account information, Social Security numbers, Social Insurance numbers, passport numbers, driver's license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other financial or health information.

NOTE: HubSpot is NOT responsible for the information we collect.

When you subscribe to our newsletter, the data (e.g. e-mail address) you provide during the registration process will be forwarded to Hubspot and stored there. The service provider is based in the USA and the data is processed on servers in the USA.

Your Opt-Out Rights Regarding Your Personal Information

If you provide us with your Personal Information, you have the following rights with respect to that information:

  • To review the user information that you have supplied to us
  • To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
  • To request that your user information not be used to contact you
  • To request that your user information be removed from any solicitation list that we use
  • To request that your user information be deleted from our records

To exercise any of these rights, please contact us. We will promptly change, correct, or delete your information and notify you of the action we have taken.

To Unsubscribe from Our Communications

You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our emails, by contacting us, or by clicking the link below. Customers cannot opt out of receiving transactional emails related to their accounts.

Who Has Access to Your Personal Information?

Assuaged Foundation, Inc., and Assuaged, Inc., dba Be Your Highest, employees have access to your personal information, and we also employ other companies and people to provide services (such as website development, for example) and they have access to your information, as well. These people understand that your Personal Information is confidential and can only be used in accordance with this privacy policy. 

On rare occasions, a trusted third party might ask us about the demographic makeup of our contact database. In these instances, we might provide statistical information about our database in aggregate, but never any information that could be used to identify any individual user.

We Keep Your Personal Information Secure

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure.

Retention of Personal Information

We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about the Subscription Service or our other services, and then we securely delete the information. We will delete this information from the servers at an earlier date if you so request, as described in the opting out and unsubscribing sections above.

International Transfer of Information

Assuaged Foundation, Inc., and Assuaged, Inc., dba Be Your Highest, is based in the United States, but we have serviced customers in other countries, as well. This Privacy Policy shall apply even if we transfer Personal Information to other countries.  

The data protection laws vary significantly across different countries and jurisdictions in terms of what categories of personal data are protected and the extent of their protection. Assuaged Foundation's data centers are located in the United States. If your personal data are transferred out of the jurisdiction where you reside, such as to Assuaged Foundation’s service providers or partners in other countries, including in the United States, different standards may govern what rights you have in those countries relating to your personal data. For purposes of cross-border transfers of personal data where subject to applicable law (such as in the European Economic Area and the United Kingdom), we rely on the consent of individuals who directly use our Sites and Services and will implement approved transfer mechanisms where required by applicable law.

Assuaged Foundation takes reasonable precautions, in accordance with applicable legal requirements and in consideration of the nature, scope, context, and purposes of its processing activities, to protect your personal data, irrespective of the country in which the data are processed. These precautions may include, where appropriate, contract clauses with third-party providers or other compliance mechanisms.  Certain Services allow our members and Users to make international data transfers to third parties, for which those members and Users are solely responsible.

What Happens If We Go Away?

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy, or otherwise, that company would receive all information gathered by our Websites and the Subscription Service.

Important! Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights or to comply with a law, court order, or legal process.

Your Personal Information and Social Media, External Websites, and Public Forums

Social Media

Our Websites includes Social Media Features, such as the Facebook sharing button. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites

Our Websites occasionally provides links to other websites. We are not in control of these websites, so we're not responsible for the content and privacy practices of these websites. These links do not constitute our endorsement of these other websites, their content, their owners, or their practices.

How We Use Navigational Information

We use Navigational Information to operate and improve our Websites and the Subscription Service. Read below for specifics.

Cookies

We use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize pages on our Websites, or register for the Subscription Service, a cookie helps us to recall your specific information on subsequent visits in what is referred to as "Smart Content". When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.

Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience interactive features on our Websites or Subscription Service. We keep track of pages you visit in order to determine the most popular or most used. This data is used to deliver better customized content and promotions.

Log Files

We may collect demographic information, such as your ZIP code, Postal code, age, gender, preferences, interests, and favorites using log files that are not associated with your name or other personally identifying information.

There is also information about your computer hardware and software that we automatically collect. This information can include your IP address, browser type, domain names, access times, and referring website addresses. For these purposes, we do link this automatically-collected data to Personal Information, such as name, email address, address, and phone number.

Third Party Tracking Technologies

The use of cookies (such as flash cookies) and web beacons by any tracking utility company is not covered by our privacy statement. We do not have access or control over these third party tracking technologies.

QUESTIONS

Any questions about this Privacy Policy should be addressed to hello@assuaged.com.