Privacy Policy

08/04/2018

1. OVERVIEW

The Bartholomew Method obtains Personal Data about you to provide our Services and to manage our Sites. “You” may be a Visitor, a User, or a Member of/to one of our websites/services.

2. PERSONAL DATA

  1. Personal Data We Collect From You

Personal Data is any information that relates to an identifiable individual. The Personal Data that you provide directly to us through our Sites will be apparent from the context in which you provide the data.  In particular:

  • When you register for a Bartholomew Method account we collect your full name, email address, and account log-in credentials.
  • When you fill-in our online form, we collect your full name, work email, country, and anything else you tell us about yourself and your needs.
  • When you use the “Remember Me” feature of Bartholomew Method Checkout, we collect your email address, payment card number, CVC code and expiration date.

When you respond to Bartholomew Method emails or surveys, we collect your email address, name, and any other information you choose to include in the body of your email or responses.  If you contact us by phone, we will collect the phone number you use to call Bartholomew Method. When you contact us by phone, we may collect additional information in order to verify your identity.  As part of your Personal Data, we may also request personal information about you, such as your date of birth.

When you make payments or conduct transactions through a Bartholomew Method website or application, we will receive your transaction information.  We may receive this information directly from you, or from the Bartholomew Method website, or third parties. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, and date of purchase.  Different payment methods may require the collection of different categories of information. The payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you by the Bartholomew Method website.

When we conduct fraud monitoring, prevention and detection activities, we may also receive Personal Data about you from our business partners, financial service providers, identity verification services, and publicly available sources, as necessary to confirm your identity and prevent fraud.  Our fraud monitoring, detection and prevention services may use technology that helps us assess the risk associated with an attempted transaction that is enabled on the Bartholomew Method website or the application that collects information.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

  1. Information That We Collect Automatically On Our Sites.

Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our Sites, including:

  • Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
  • Usage data, such as time spent on the Sites, pages visited, links clicked, email reception/response, language preferences, and the pages that led or referred you to our Sites.

We also may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services.  We use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues.

3. HOW WE USE PERSONAL DATA

  1. Our Products and Services.

We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law.  We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests.  We also use Personal Data to complete payment transactions and to provide payment-related services to our Users.

  1. Marketing and Events-Related Communications.

We may send you email marketing communications about Bartholomew Method products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law.  When we collect your contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

  1. Interest-Based Advertising.

When you visit our Sites or online services, both we and certain third parties may collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser (including the use of pixel tags). Where required by applicable law, we will obtain your consent prior to the processing of your information for the purpose of interest-based advertising.

You may see our ads on other websites or mobile apps because we participate in advertising networks.  Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.

We work with Google AdWords, Doubleclick, AdRoll and other advertising networks.  To learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initative and Digital Advertising Alliance.  You may download the AppChoices app to opt out in mobile apps. If you opt out of interest-based advertising, you may see advertising that is not relevant to you.  At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.

4. HOW WE DISCLOSE PERSONAL DATA

The Bartholomew Method does not sell or rent Personal Data to marketers or unaffiliated third parties.  We share your Personal Data with trusted entities, as outlined below.

  1. The Bartholomew Method.  We share Personal Data with other Bartholomew Method entities in order to provide our Services and for internal administration purposes.
  2. Service providers.  We share Personal Data with a limited number of our service providers.  We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services.  These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.
  3. Business partners.  We share Personal Data with third party business partners when this is necessary to provide our Services to our Users.  Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when we provide payment processing services.
  4. Our Users and third parties authorized by our Users.  We share Personal Data as necessary to maintain a User account and provide Services.  We share data with parties directly authorized by a User to receive Personal Data, such as when a User authorizes a third party application provider to access the User’s Bartholomew Method account.  The use of Personal Data by an authorized third party is subject to the third party’s privacy policy.
  5. Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.
  6. Compliance and harm prevention.  We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of the Bartholomew Method, you, or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.

5. YOUR RIGHTS AND CHOICES

You have choices regarding our use and disclosure of your Personal Data:

  1. Opting out of receiving electronic communications from us.  If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.
  2. How you can change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your Bartholomew Method account, or by contacting us.
  3. Your data protection rights.  Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we retain about you:
  • The right to request confirmation of whether Bartholomew Method processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
  • The right to request that Bartholomew Method rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
  • The right to request that Bartholomew Method erase your Personal Data in certain circumstances;
  • The right to request that Bartholomew Method restrict the use of your Personal Data in certain circumstances, such as while Bartholomew Method considers another request that you have submitted (including a request that Bartholomew Method make an update to your Personal Data); and
  • The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.

Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time.  You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

  1. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact Bartholomew Method as described in the Contact Us section below. We take each request seriously.  We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with a United States data protection authority. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.  If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

6. SECURITY AND RETENTION

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data.  We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse.  Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

If you are a Bartholomew Method User, we retain your Personal Data as long as we are providing the Services to you.  We retain Personal Data after we cease providing Services to you, even if you close your Bartholomew Method account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention.  We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support.  Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

7. INTERNATIONAL DATA TRANSFERS

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States.  Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

8. USE BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.

9. UPDATES TO THIS PRIVACY POLICY AND NOTIFICATIONS

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices, or relevant laws.  The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the websites.  We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your email address and/or the physical address listed in your Bartholomew Method account.

10. LINKS TO OTHER WEBSITES

The Bartholomew Method may provide the ability to connect to other websites.  These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review.  If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

11. JURISDICTION-SPECIFIC PROVISIONS

California residents.  If you are a California resident, then, subject to certain limits under California law, you may ask us to provide you with (i) a list of certain categories of Personal Data we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; and (ii) the identity of those third parties.  To make this request, California residents may contact us as specified in the Contact Us section below.

12. CONTACT US

If You have any questions or complaints about this Privacy Policy, please contact us electronically or send physical mail to:

830 Traction Avenue

2nd Floor, The Hub

Los Angeles, CA 90013

Attn: Bartholomew Method Legal