Privacy Policy

<!DOCTYPE HTML PUBLIC "-//W3C//DTD HTML 4.0 Transitional//EN"><HTML><HEAD> <META HTTP-EQUIV="CONTENT-TYPE" CONTENT="text/html; charset=utf-8"> <TITLE></TITLE> <META NAME="GENERATOR" CONTENT="LibreOffice 4.1.6.2 (Linux)"> <META NAME="CREATED" CONTENT="20170611;213800000000000"> <META NAME="CHANGEDBY" CONTENT="James Chiodo"> <META NAME="CHANGED" CONTENT="20180816;5200000000000"> <META NAME="AppVersion" CONTENT="16.0000"> <META NAME="Company" CONTENT="Microsoft"> <META NAME="DocSecurity" CONTENT="0"> <META NAME="HyperlinksChanged" CONTENT="false"> <META NAME="LinksUpToDate" CONTENT="false"> <META NAME="ScaleCrop" CONTENT="false"> <META NAME="ShareDoc" CONTENT="false"> <STYLE TYPE="text/css">  @page { size: 8.5in 11in; margin-left: 1in; margin-right: 1in; margin-top: 1in; margin-bottom: 0.5in } P { margin-bottom: 0.08in; direction: ltr; font-size: 12pt; widows: 2; orphans: 2 } H2 { margin-bottom: 0.04in; direction: ltr; color: #000000; widows: 2; orphans: 2; text-decoration: none } H2.western { font-family: "Arial Unicode MS", sans-serif; font-size: 12pt; font-weight: normal } H2.cjk { font-size: 12pt; font-weight: normal } H2.ctl { font-family: "Arial Unicode MS"; font-size: 12pt; font-weight: normal } H3 { margin-bottom: 0.08in; direction: ltr; color: #000000; text-align: justify; widows: 2; orphans: 2; text-decoration: underline } H3.western { font-family: "Calibri", sans-serif } H3.cjk { font-family: "Calibri" } H3.ctl { font-family: "Calibri" } H4 { margin-top: 0.14in; margin-bottom: 0.08in; direction: ltr; color: #4f81bd; line-height: 115%; page-break-inside: avoid; widows: 2; orphans: 2; text-decoration: none } H4.western { font-family: "Cambria", sans-serif; font-size: 11pt; font-style: italic } H4.cjk { font-family: "Cambria"; font-size: 11pt; font-style: italic } H4.ctl { font-family: "Cambria"; font-size: 11pt; font-style: italic } A:link { so-language: zxx } --> </STYLE></HEAD><BODY LANG="en-US" DIR="LTR"> <H2 CLASS="western">PrivacyNotice EffectiveDate: Notice Version: 1.0</H2><H2 CLASS="western">DataController Contact Information</H2>BreakFree From AnxietyPOBox 325 RamonaCA 92065 [email protected] Thisdocument governs the privacy notice of our websitewww.BreakFreeFromAnxiety.com.<H3 CLASS="western" STYLE="page-break-after: auto">Ourprivacy notice tells you what personal data (PD) and non-personaldata (NPD) we may collect from you, how we collect it, how we protectit, how we may share it, how you can access and change it, and howyou can limit our sharing of it. Our privacy notice also explainscertain legal rights that you have with respect to your personaldata. Any capitalized terms not defined herein will have the samemeaning as where they are defined elsewhere on our website.</H3> YourRightsWhenusing our website and submitting personal data to us, you may havecertain rights under the General Data Protection Regulation (GDPR)and other laws. Depending on the legal basis for processing yourpersonal data, you may have some or all of the following rights: Theright to be informedYouhave the right to be informed about the personal data we collect fromyou, and how we process it.  Theright of accessYouhave the right to get confirmation that your personal data is beingprocessed and have the ability to access your personal data. Theright to rectification Youhave the right to have your personal data corrected if it isinaccurate or incomplete. Theright to erasure (right to be forgotten) Youhave the right to request the removal or deletion of your personaldata if there is no compelling reason for us to continue processingit. Theright to restrict processing Youhave a right to ‘block’ or restrict the processing of yourpersonal data. When your personal data is restricted, we arepermitted to store your data, but not to process it further. Theright to data portabilityYouhave the right to request and get your personal data that youprovided to us and use it for your own purposes. We will provide yourdata to you within 30 days of your request. To request your personaldata, please contact us using the information atthe top of this privacy notice. Theright to object Youhave the right to object to us processing your personal data for thefollowing reasons:<UL> <LI> Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); <LI> Direct marketing (including profiling); and <LI> Processing for purposes of scientific/historical research and statistics. <LI> Rights in relation to automated decision-making and profiling.</UL>Automatedindividual decision-making and profilingYouwill have the right not to be subject to a decision based solely onautomated processing, including profiling, which produces legaleffects concerning you or similarly significantly affects you. Filinga complaint with authoritiesYouhave the right to file a complaint with supervisory authorities ifyour information has not been processed in compliance with theGeneral Data Protection Regulation. If the supervisory authoritiesfail to address your complaint properly, you may have the right to ajudicial remedy. Fordetails about your rights under the law, visit <A HREF="https://goo.gl/F41vAV">https://goo.gl/F41vAV</A> Definitions‘Non-personaldata’ (NPD) is information that is in noway personally identifiable. ‘Personaldata’ (PD) means anyinformation relating to an identified or identifiable natural person(‘data subject’); an identifiable natural person is one who canbe identified, directly or indirectly, by reference to an identifiersuch as a name, an identification number, location data, an onlineidentifier or to one or more factors specific to the physical,physiological, genetic, mental, economic, cultural or social identityof that natural person. PD is in many ways the same as PersonallyIdentifiable Information (PII). However, PD is broader in scope andcovers more data. A“visitor” issomeone who merely browses our website. A “member”is someone who has registered with us to use or buy our services andproducts. The term “user”is a collective identifier that refers to either a visitor or amember. TopicsCovered in Our Privacy notice<H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">InformationWe Collect</H3><H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">OurUse of Cookies How Your Information Is Used Retaining andDestroying Your PD Updating Your PD</H3><H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">RevokingYour Consent for Using Your PD</H3>Protectingthe Privacy Rights of Third Parties<H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">DoNot Track Settings</H3><H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">Linksto Other Websites</H3><H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">ProtectingChildren’s Privacy</H3><H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">OurEmail Policy Our Security Policy</H3><H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">Useof Your Credit Card</H3>TransferringPD from the European Union<H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">Changesto Our Privacy Notice</H3> <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">InformationWe Collect</H3>Generally,you control the amount and type of information that you provide to uswhen using our website.OurLegal Basis for Collecting and Processing Personal DataOur legalbasis for collecting and processing your PD when you buy ourproducts, services, or contact us through our website contact formsabout our products and services is based on and the necessity for theperformance of a contract or to take steps to enter into a contract.Our legal basis for collecting and processing your PD when you signup for our newsletter, download our free information through ourwebsite opt-in forms is based on consent. WhatHappens If You Don’t Give Us Your PD Ifyou do not provide us with enough PD, we may not be able to provideyou with all our products and services. However, you can access anduse some parts of our website without giving us your PD. WeCollect Your PD in the Following Ways: <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto">AutomaticInformation</H4>Weautomatically receive information from your web browser or mobiledevice. This information includes the name of the website from whichyou entered our website, if any, as well as the name of the websiteyou’ll visit when you leave our website. This information alsoincludes the IP address of your computer/the proxy server you use toaccess the Internet, your Internet service provider’s name, yourweb browser type, the type of mobile device, your computer operatingsystem, and data about your browsing activity when using our website.We use all this information to analyze trends among our users to helpimprove our website.<H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto"> </H4>WhenEntering and Using Our WebsiteWhenyou enter and use our website and agree to accept cookies, some ofthese cookies may contain your PD. <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto">AtUser and Member Registration or When BuyingProducts or Services</H4>Whenyou register as a user, member, or when buying our products orservices, we may collect some or all of the following information:your first and last name, email address, physical address, creditcard or other payment information, phone number, user name, password,and other information listed.  <H3 CLASS="western">Our Use ofCookies</H3>Ourwebsite uses cookies. A cookie is a small piece of data or a textfile that is downloaded to your computer or mobile device when youaccess certain websites. Cookies may contain text that can be read bythe web server that delivered the cookie to you. The text containedin the cookie generally consists of a sequence of letters and numbersthat uniquely identifies your computer or mobile device; it maycontain other information as well.  Byagreeing to accept our use of cookies, you are giving us, and thirdparties we partner with, permission to place, store, and access someor all the cookies described below on your computer. StrictlyNecessary Cookies Thesecookies are necessary for proper functioning of the website, such asdisplaying content, logging in, validating your session, respondingto your request for services, and other functions. Most web browserscan be set to disable the use of cookies. However, if you disablethese cookies, you may not be able to access features on our websitecorrectly or at all.  <A NAME="_Hlk483049964"></A>PerformanceCookies Thesecookies collect information about the use of the website, such aspages visited, traffic sources, users’ interests, contentmanagement, and other website measurements. FunctionalCookies Thesecookies enable the website to remember a user’s choices – such astheir language, user name, and other personal choices – while usingthe website. They can also be used to deliver services, such asletting a user make a blog post, listen to audio, or watch videos onthe website. MediaCookies Thesecookies can be used to improve a website’s performance and providespecial features and content. They can be placed by third parties whoprovide services to us or by our company. Advertisingor Targeting Cookies Thesecookies are usually placed and used by advertising companies todevelop a profile of your browsing interests and serve advertisementson other websites that are related to your interests. You will seeless advertising if you disable these cookies. SessionCookies Thesecookies allow websites to link the actions of a user during a browsersession. They may be used for a variety of purposes, such asremembering what a user has put in their shopping cart as they browsea website. Session cookies also permit users to be recognized as theynavigate a website so that any item or page changes they make areremembered from page to page. Session cookies expire after a browsersession; thus, they are not stored long term.  PersistentCookies These cookies are stored on auser’s device in between browser sessions, which allows the user’spreferences or actions across a site (or, in some cases, acrossdifferent sites) to be remembered. Persistent cookies may be used fora variety of purposes, including remembering users’ choices andpreferences when using a website or to target advertising to them. Wemay also use cookies for:<UL> <LI>Identifying the areas of our website that you have visited <LI>Personalizing content that you see on our website <LI>Our website analytics <LI>Remarketing our products or services to you <LI>Remembering your preferences, settings, and login details <LI>Targeted advertising and serving ads relevant to your interests <LI>Affiliate marketing <LI>Allowing you to post comments <LI>Allowing you to share content with social networks</UL> Mostweb browsers can be set to disable the use of cookies. However, ifyou disable cookies, you may not be able to access features on ourwebsite correctly or at all.  <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto">WebBeacons </H4>Wemay also use a technology called web beacons to collect generalinformation about your use of our website and your use of specialpromotions or newsletters. The information we collect by web beaconsallows us to statistically monitor the number of people who open ouremails. Web beacons also help us to understand the behavior of ourcustomers, members, and visitors.  <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto">GoogleAnalytics Privacy Notice</H4>Ourwebsite uses Google Analytics to collect information about the use ofour website. Google Analytics collects information from users such asage, gender, interests, demographics, how often they visit ourwebsite, what pages they visit, and what other websites they haveused before coming to our website. We use the information we get fromGoogle Analytics to analyze traffic, remarket our products andservices to users, improve our marketing, advertising, and to improveour website. We have enabled Google Analytics advertising featuressuch as remarketing with Google Analytics, Google Display NetworkImpression Reporting, and Google Analytics Demographics and InterestReporting. Google Analytics collects only the IP address assigned toyou on the date you visit our website, not your name or otheridentifying information. We do not combine the information collectedusing Google Analytics with PD. Although Google Analytics plants apermanent cookie on your web browser to identify you as a unique userthe next time you visit our website, the cookie cannot be used byanyone but Google. Google also uses specific identifiers to helpcollect information about the use of our website. For moreinformation on how Google collects and processes your data, visithttps://www.google.com/policies/privacy/partners/Youcan prevent Google Analytics from using your information by optingout at this link: https://tools.google.com/dlpage/gaoptout<H3 CLASS="western" ALIGN=LEFT STYLE="text-decoration: none; page-break-after: auto"> </H3>FacebookRemarketingThirdparties, including Facebook, may use cookies, web beacons, and otherstorage technologies to collect or receive information from ourwebsite and elsewhere on the internet, and use that information toprovide measurement services and target ads. With Facebookremarketing you may see our ads on Facebook after you have visitedour site. For this to happen, Facebook uses a Custom Audience Pixelthat is activated when a visitor lands on a webpage and a unique“cookie” is placed in their browser. Facebook lookalike audiencetargeting allows us to show ads on Facebook to people who are similarto those who have already visited or made a purchase from ourwebsite. To opt out of Facebook’s collection and use of informationfor ad targeting visit: <A HREF="https://www.facebook.com/help/568137493302217">https://www.facebook.com/help/568137493302217</A> <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">HowYour Information Is Used </H3>Weuse the information we receive from you to: <UL> <LI> Provide our products and services you have requested or purchased from us <LI> To answer your questions about your anxiety and health issues <LI> Make improvements to our website <LI> Contact you with updates to our website <LI> Resolve problems and disputes <LI> Contact you with marketing and advertising that we believe may be of interest to you</UL> <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto"><A NAME="_GoBack"></A>Communicationsand Emails</H4>Whenwe communicate with you about our website, we will use the emailaddress you provided when you registered as a member or user. We mayalso send you emails with promotional information about our websiteor offers from us or our affiliates unless you have opted out ofreceiving such information. You can change your contact preferencesat any time through your account or by sending us an email with yourrequest to: [email protected] SharingInformation With Affiliates and Other Third PartiesWedo not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD,which might be sold to other parties at our discretion. Any such dataaggregation would not contain any of your PD. We may provide your PDto third-party service providers we hire to provide services to us.These third-party service providers may include but are not limitedto: payment processors, web analytics companies, advertisingnetworks, call centers, data management services, help deskproviders, accountants, law firms, auditors, shopping cart and emailservice providers, and shipping companies. <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%">SharingInformation With Facebook and Google for Marketing Purposes Wemay share your PD with third parties for similar audience marketingpurposes. Similar audience marketing is also called lookalikeaudience marketing.The third parties we share your PD with for this type of marketinginclude Facebook and/or Google. Using your PD, for similar audiencemarketing or lookalikeaudience marketing helpsus find new audiences (users and customers) based on similarinterests to yours, this helps us improve our marketing services.Your PD is only shared with Facebook and Google for this type ofmarketing. By using our website and agreeing to our privacy notice,you are giving your consent for your PD to be used for the marketingpurposes described within this section.</H4> <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto">LegallyRequired Releases of Information</H4>Wemay be legally required to disclose your PD if such disclosure is (a)required by subpoena, law, or other legal process; (b) necessary toassist law enforcement officials or government enforcement agencies;(c) necessary to investigate violations of or otherwise enforce ourLegal Terms; (d) necessary to protect us from legal action or claimsfrom third parties, including you and/or other users or members; or(e) necessary to protect the legal rights, personal/real property, orpersonal safety of our company, users, employees, and affiliates. <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto">Disclosuresto Successors</H4>Ifour business is sold or merges in whole or in part with anotherbusiness that would become responsible for providing the website toyou, we retain the right to transfer your PD to the new business. Thenew business would retain the right to use your PD according to theterms of this privacy notice as well as to any changes to thisprivacy notice as instituted by the new business. Wealso retain the right to transfer your PD if our company files forbankruptcy and some or all of our assets are sold to anotherindividual or business. <H4 CLASS="western" STYLE="margin-top: 0in; line-height: 100%; page-break-inside: auto; page-break-after: auto">CommunityDiscussion Boards</H4>Our website may offer the ability forusers to communicate with each other through online communitydiscussion boards or other mechanisms. We donot filter or monitor what isposted on such discussion boards. If you choose to post on thesediscussion boards, you should use care when exposing any PD, as suchinformation is not protected by our privacy notice nor are we liableif you choose to disclose your PD through such postings. Also,PD you post on our website for publication may be available worldwideby means of the Internet. Wecannot prevent the useor misuse of such information byothers. Retainingand Destroying Your PDWe retaininformation that we collect from you (including your PD) only for aslong as we need it for legal, business, or tax purposes. Yourinformation may be retained in electronic form, paper form, or acombination of both. When your information is no longer needed, wewill destroy, delete, or erase it.<H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto"> </H3><H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">UpdatingYour PD</H3>Youcan update your PD using services found on our website. If no suchservices exist, you can contact us using the contact informationfound at the top of this notice and we will help you. However,we may keep your PD as needed to enforce our agreements and to complywith any legal obligations. <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">RevokingYour Consent for Using Your PD </H3>Youhave the right to revoke your consent for us to use your PD at anytime. Such an optout will not affect disclosures otherwise permittedby law including but not limited to: (i) disclosures to affiliatesand business partners, (ii) disclosures to third-party serviceproviders that provide certain services for our business, such ascredit card processing, computer system services, shipping, datamanagement services, (iii) disclosures to third parties as necessaryto fulfill your requests, (iv) disclosures to governmental agenciesor law enforcement departments, or as otherwise required to be madeunder applicable law, (v) previously completed disclosures to thirdparties, or (vi) disclosures to third parties in connection withsubsequent contests or promotions you may choose to enter, orthird-party offers you may choose to accept. If you want to revokeyour consent for us to use your PD, send us an email with yourrequest to: [email protected] Protectingthe Privacy Rights of Third PartiesIfany postings you make on our website contain information about thirdparties, you must make sure you have permission to include thatinformation in your posting. While we are not legally liable for theactions of our users, we will remove any postings about which we arenotified, if such postings violate the privacy rights of others. <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">DoNot Track Settings</H3>Someweb browsers have settings that enable you to request that ourwebsite not track your movement within our website. Our website doesnotobey such settings when transmittedto and detected by our website. You can turn off tracking featuresand other security settings in your browser by referring to yourbrowser’s user manual. <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">Linksto Other Websites</H3>Ourwebsite may contain links to other websites. These websites are notunder our control and are not subject to our privacy notice. Thesewebsites will likely have their own privacy notices. We have noresponsibility for these websites and we provide links to thesewebsites solely for your convenience. You acknowledge that your useof and access to these websites are solely at your risk. It is yourresponsibility to check the privacy notices of these websites to seehow they treat your PD. <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto"> </H3><H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">ProtectingChildren’s Privacy</H3>Eventhough our website is not designed for use by anyone under the age of16, we realize that a child under the age of 16 may attempt to accessour website. We do not knowingly collect PD from children under theage of 16. If you are a parent or guardian and believe that yourchild is using our website, please contact us. Before we remove anyinformation, we may ask for proof of identification to preventmalicious removal of account information. If we discover that a childis accessing our website, we will delete his/her information within areasonable period of time. You acknowledge that we do not verify theage of our users nor do we have any liability to do so.  <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">OurEmail Policy</H3>Youcan always opt out of receiving further email correspondence from usor our affiliates. We will not sell, rent, or trade your emailaddress to any unaffiliated third party without your permissionexcept in the sale or transfer of our business, or if our companyfiles for bankruptcy. <H3 CLASS="western" STYLE="page-break-after: auto">OurSecurity Policy</H3><A NAME="_Hlk497734378"></A>We have built our website usingindustry-standard security measures and authentication tools toprotect the security of your PD. We and the third parties who provideservices for us, also maintain technical and physical safeguards toprotect your PD. When we collect your credit card information throughour website, we will encrypt it before it travels over the Internetusing industry-standard technology for conducting secure onlinetransactions. Unfortunately, we cannot guarantee against the loss ormisuse of your PD or secure data transmission over the Internetbecause of its nature. Westrongly urge you to protect any password you may have for ourwebsite and to not share it with anyone. You should always log out ofour website when you finish using it, especially if you are sharingor using a computer in a public place. <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">Useof Your Credit Card</H3>Youmay have to provide a credit card to buy products and services fromour website. We use third-party billing services and have no controlover these services. We use our commercially reasonable efforts tomake sure your credit card number is kept strictly confidential byusing only third-party billing services that use industry-standardencryption technology to protect your credit card number fromunauthorized use. However, you understand and agree that we are in noway responsible for any misuse of your credit card number.  TransferringPD From the European Union(PD) thatwe collect from you may be stored, processed, and transferred betweenany of the countries in which we operate, specifically United States.The European Union has notfound the United States and some other countries to have an adequatelevel of protection of PD under Article 45 of the GDPR. Our companyrelies on derogations for specific situations as defined in Article49 of the GDPR. For European Unioncustomers and users, with your consent, your PD may be transferredoutside the European Union to the United States and or othercountries. We will use your PD to provide the goods, services, and/orinformation you request from us to perform a contract with you or tosatisfy a legitimate interest of our company in a manner that doesnot outweigh your freedoms and rights. Wherever we transfer, processor store your PD, we will take reasonable steps to protect it. Wewill use the information we collect from you in accordance with ourprivacy notice. By using our website, services, or products, youagree to the transfers of your PDdescribed within this section. <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">Changesto Our Privacy notice</H3>Wereserve the right to change this privacy notice at any time. If ourcompany decides to change this privacy notice, we will post thosechanges on our website so that our users and customers are alwaysaware of what information we collect, use, and disclose. If at anytime we decide to disclose or use your PD in a method different fromthat specified at the time it was collected, we will provide advancenotice by email (sent to the email address on file in your account).Otherwise we will use and disclose our users’ and customers’ PDin agreement with the privacy notice in effect when the informationwas collected. In all cases, your continued use of our website,services, and products afterany change to this privacy notice will constitute your acceptance ofsuch change. <H3 CLASS="western" ALIGN=LEFT STYLE="page-break-after: auto">QuestionsAbout Our Privacy notice</H3>Ifyou have any questions about our privacy notice, please contact ususing the information at the top of this privacy notice. Copyright© Orion Systems. 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