Privacy Policy

 

At WINNERS CIRCLE, we take privacy issues seriously. By ensuring that you are aware of and understand the WINNERS CIRCLE Privacy Policy, we can provide you with better service. Please take a moment to read the following policy to learn how we handle your personal information.

Why do we collect personal information?

WINNERS CIRCLE collects personal information to improve the manner by which we operate, offer our products and services, communicate with you about those products and services, and provide effective, timely customer support when needed. We will never rent or sell any of the personal information we collect from you to third parties, and we do not share your personal information except as set forth in this Privacy Policy.

What kind of personal information do we collect?

WINNERS CIRCLE collects personal information in a variety of ways when you interact with WINNERS CIRCLE, including when you register or create an account with WINNERS CIRCLE; when you place an order at WINNERS CIRCLE; when you use WINNERS CIRCLE products or services; when you visit WINNERS CIRCLE pages or pages of certain WINNERS CIRCLE partners; when you enter promotions or sweepstakes; when you subscribe to a newsletter or desire to be added to our mailing lists for other products or services; when you correspond or otherwise interact with us; and when you provide feedback in any of our online surveys.

Information we collect may include: your name, e-mail address, phone number, address, product preference information, billing information, demographic information provided by you (such as language, gender and age, and, if applicable, content preferences and personalization information) and personal interest information. On occasion, we may ask for additional information to enable us to provide with access to and use of certain information, materials and services. WINNERS CIRCLE may combine information about you that we have the information we obtain from business partners or other companies.

What are cookies and how do we use them?

Cookies are small data files that write to your hard drive for record keeping purposes when you visit a website. Cookies allow WINNERS CIRCLE to measure traffic activity as well as to improve your user experience, for example by remembering your passwords and viewing preferences. Like other major websites, WINNERS CIRCLE uses cookies to provide you with a tailored experience when visiting WINNERS CIRCLE and using our major products. We treat any personal information that may be contained in cookies with the same level of confidentiality as other information you provide to us. If you wish to disable cookie functionality, you may do so by changing the security settings on your browser. However, portions of WINNERS CIRCLE may not function or function as efficiently, without them.

 What information is collected from other sources?

Social Media Widgets:

The Websites include 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 Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, 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 the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information From Third Party Services:

We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third-party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social media or authentication service is in accordance with the authorization procedures determined by that service. If you authorize us to connect with a third-party service, we will access and store your name, email address(es), current city, profile picture URL, and other personal information that the third-party service makes available to us, and use and disclose it in accordance with this Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services. For example, you can log in to the Services using single sign-in services such as Facebook Connect or an Open ID provider.

These single sign-on services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities in the Services to your profile page to share with others within your network.

How do we protect your personal information?

WINNERS CIRCLE safeguards the security of the data you send us with physical, electronic, and managerial procedures. We urge you to take every precaution to protect your personal data when you are on the Internet. To make purchases from WINNERS CIRCLE web site, you must use an SSL-enabled browser. WINNERS CIRCLE uses industry-standard Secure Sockets Layer (SSL) encryption on web pages used to complete a purchase. This protects the confidentiality of your personal and credit card information while it is transmitted over the Internet.

While WINNERS CIRCLE takes precautions to ensure the security of your data, no one can completely guarantee the safety of data transmitted over the internet. It is important that you take steps to ensure the safety and security of your personal information, for example by not sharing passwords or other registration data.

How do we use your personal information?

WINNERS CIRCLE uses your personal information in the following ways:

  • Delivery and billing for our products and services, and to communicate with you concerning your account and customer service issues. This may include verifying authorization of credit card usage before any purchase of content or services.
  • Improving our products and services by providing personalized content recommendations, language and location customization, and/or personalized help and instructions.
  • To ask you to participate in surveys about products, services, news and events.
  • Offering you product upgrades, content, services and other training courses for you to purchase.
  • Providing provide you with content, services, instructions, and a more personalized experience based on personal information, such as your language preferences, zip/postal code, country locations, and any content or other preferences you provide.
  • Providing you with news, free newsletters, updates, targeted advertising, promotions, and special offers.
  • To better understand how our products are used, including Web traffic patterns and what types of content are most popular with users of our products and services.
  • Providing anonymous reporting for internal and external partners.
  • Facilitating your participation in our online forums and helping to manage improper behavior by individuals using the forums.

How and when we disclose your information we collect.

WINNERS CIRCLE may share your personal information with trusted vendors and partners who work with WINNERS CIRCLE. These partners are provided with your personal information to help WINNERS CIRCLE communicate with you about offers from us and from our marketing partners. They are contractually required to keep this personal information secure and to only use it for the purposes for which it is provided. WINNERS CIRCLE may send personal information about you to other companies or people when we need to share your information to provide the product or service you have requested or to provide a provide a product or service to you. However, these companies are only permitted to use the personal information for these purposes.

WINNERS CIRCLE may also disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with law or legal process or if requested by duly authorized public authorities; (b) comply with the order of a competent judicial authority in any jurisdiction; (c) comply with legal process served on WINNERS CIRCLE; (d) protect and defend the rights or property of WINNERS CIRCLE, or our affiliated companies, their employees and agents; (e) enforce our terms of use; (f) protect against fraud or other illegal activity or for risk management purposes; (g) permit us to pursue available remedies or limit the damages that we may sustain; (g) act in urgent circumstances to protect the personal safety of users of WINNERS CIRCLE products or the public at large.

If WINNERS CIRCLE should ever file for bankruptcy, or become insolvent, or be acquired by a third party, or merge with a third party, or sell all or part of its assets, or transfer substantially all or part of its relevant assets to a third party, then WINNERS CIRCLE is entitled to share the personal information and all other information you have provided through the products and service to potential and subsequent business and merger partners.

WINNERS CIRCLE may share “cookie” and other anonymous data about traffic patterns or usage collected on WINNERS CIRCLE with affiliated companies, its business partners or with third party advertisers or ad networks. Any data shared is anonymous and does not identify any user.

WINNERS CIRCLE may also include third party advertising. These third parties’ websites and advertisers, or the Internet advertising companies that work on their behalf, may use technology such as web beacons and cookies to send (or “serve”) the advertisements that appear on our Site directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, electronic images and other technologies to deliver advertisements, collect information about the effectiveness of their advertisements, and to collect anonymous information about your visits to WINNERS CIRCLE, such as the number of times you have viewed an ad (but not your name, address, or other personal information).

WINNERS CIRCLE also contains links to other Websites and products. WINNERS CIRCLE is not responsible for the privacy practices or the content of such Websites or products. Please visit the privacy policies of these third party sites in order to understand their privacy policies and data collection practices.

What rights do you have regarding your data?

You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection.

You may also, of course, file a complaint with the competent regulatory authorities.

Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient.

The data processed before we receive your request may still be legally processed.

If you no longer wish to receive communications from WINNERS CIRCLE, you can opt-out from receiving such messages in the future by following the instructions in the message or contacting us at [email protected]

With respect to the Site’s use of cookies and other similar technologies, by adjusting settings on your browser, you may elect not to allow cookies to be places, and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data about you.

You may also adjust your advertising preferences on various social media websites by adjusting your settings on the platform.

If you are accessing the Site from the European Economic Area, which includes the European Union, Iceland, Liechtenstein, and Norway, or you are a citizen of a member state of the European Economic Area, you have the following rights under the EU General Data Protection Regulation (GDPR).

  1. Right to be informed about the collection and use of your personal data
  2. Right to access your personal data
  3. Right to have any inaccurate personal data corrected
  4. Right to have your personal data erased
  5. Right to restrict use of your personal data
  6. Right to personal data portability
  7. Right to object to the processing of your personal data

What are the Legal reasons we collect and disclose certain information?

Legal basis for processing (EEA visitors only):

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (e.g. to provide you with our Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your personal information. If we process personal information in reliance on your consent, you may withdraw your consent at any time.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” section below.

 Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.

Testimonials:

From time to time, we may post testimonials on the Websites that may contain personal information. We obtain Your consent to post Your name along with Your testimonial. If you wish to update or delete your testimonial, you can contact us at [email protected]

Community Forums:

The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas“). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at [email protected] In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

 Notice concerning the party responsible for this website.

The party responsible for processing data on this website is:

Winners Circle Training LLC.

Lancaster, PA 

Email: [email protected] 

If you are a resident of California, California law permits you to request certain information regarding the disclosure of your personal data by WINNERS CIRCLE, make such a request, please email us at [email protected]

We respect children’s privacy in particular. We do not target knowingly or intentionally collect personally identifiable information from children under the age of 13. By using the Site, you have represented and warranted that you are either 18 years of age or using the Site with the supervision of a parent or guardian. If you are under 13, you may not use the Site. If you become aware that your child has provided us with personal information without your consent, you are urged to email us at [email protected]

If you would like to contact us for any reason regarding our privacy practices, please e-mail us at the following address: [email protected] We may change this privacy policy at any time. If we make material changes to this privacy policy, we will prominently post that the policy has changed.


 

Winners Circle Training LLC (the “Company”) respects the privacy concerns of the users of its website, www.kajabi.com and the services provided therein (the “Site”). The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information may be used.

Your use of the Company’s services and this site are also governed by those of Kajabi, LLC, a California limited liability company. Please also review the Kajabi® website Terms of Use at https://newkajabi.com/policies/terms/ and Privacy Policy of learn.winnerscircletraining.com which also govern use of this Site.

Use of Information: As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of the Company’s internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.

The Site’s various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give us contact information such as your name, mailing and/or e-mail address, demographic information such as your age and gender, and personal preference information such as your preferred software and interests. Information submitted at the time of submission will be used by the Company only as necessary for our legitimate business interests, including without limitation the improvement of our products, services and the contents of the Site. The Company may also share such information with our business and promotional partners to further those interests. Personally identifiable information is never sold or leased to any third parties. With your permission, we may use your contact information to send you information about our company and products. You may always opt-out of receiving future mailings as provided below. The Company does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.

The Company may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Site, or anyone else that could be harmed by such activities.

The Company may also be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Please also note that third-parties who provide and/or publish content via the Company’s Kajabi® Service shall be deemed the data controllers for any personal data contained in the content uploaded by any such party to the Company’s Kajabi® Service (“Third-Party Content”) and any other personal data processed in relation to such Third-Party Content. This privacy policy only concerns the processing for which the Company is data controller. If you have any questions regarding personal data contained in the Third-Party Content, please contact the third-party provider responsible for such Third Party Content.

Children Age 16 and Under: The Company recognizes the special obligation to protect personally identifiable information obtained from children age 16 and under. AS SUCH, IF YOU ARE 16 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 16 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.

Kajabi nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:

  • Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
  • Know the sites your kids are visiting and which sites are appropriate.
  • Look for Website privacy policies. Know how your child’s information is treated.
  • Check out the FTC’s site for more tips on protecting children's privacy online.

Use of Cookies: Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using our Site easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.

Kajabi uses the following cookies on the Site:

Cookie Name Purpose
_kjb_session Kajabi session cookie Tracks your active admin session so you don't need to re-login
kjba Kajabi affiliate token Tracks which affiliate has referred an offer purchase
_abv Admin bar hidden Tracks whether the user wishes their admin previewing bar to be hidden

Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

Links to External Sites: The Company is not responsible for the content or practices of third party websites that may be linked to the Site. The Company is also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective privacy policy and practices prior to disclosing any information.

Bulletin Boards and Chat Areas: Guests of the Site are solely responsible for the content of messages they post on the Company’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.

Choice/Opt-Out: The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us at [email protected], including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.

Transfer of Information Across National Borders: Our site and various information we collect are operated on servers located in various jurisdictions, including the United States. When you access or use the Site and/or our services, personal information about you may be transferred outside the country in which you are situated to these other locations. The Company’s policies ensure that such personal information is protected to the same standard when processed by any Company entity or office around the world. We also ensure that appropriate contracts containing standard data protection clauses approved by the European Commission to protect that information and the rights of individuals are in place with any and all third-party service providers we may use.

Your Access to and Control Over Your Personally Identifiable Information: At any time, but only once per calendar year, or as otherwise required under applicable law, users may contact Company to review the personally identifiable information that Company has collected about you. If you discover any errors, please notify Company and the information will be corrected. To review the personally identifiable information that company has collected about you, please send an email to [email protected] with the subject line: “Personal Information Review Request.” Users may also request that Company delete a user account(s) or, if you have not established a user account, your email address, and any related data at any time. If you wish to delete your user account(s), please email us at [email protected] with the words “Delete Account” in the subject line. If you do not have a user account and wish to delete your email address or other personally identifiable information that you might have provided through your use of the Site, any Games, and/or any Services, please email us at [email protected] with the words “Delete My Information” in the subject line.

You may also choose to confirm that the Company does not use your personal information in certain ways and/or to otherwise “opt out” of certain uses of that personal information, including without limitation (i) when your personal may to be disclosed to a third party unrelated to the Company and/or parties directly related to providing your Services and/or (ii) when your personal information may be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. If you wish to limit your personal data in either such way, or have other questions about how the Company may use your personal data, please contact us at [email protected] with the words “Privacy Request” in the subject line.

Your California Privacy Rights: California Civil Code Section 1798.83 permits California residents to request from companies conducting business in California a list of third parties to which the company has disclosed personally identifiable information during the preceding year for direct marketing purposes. Company has not and will not share your personally identifiable information with third parties for their direct marketing purposes; accordingly, it will not maintain such a list of third parties. If you are a resident of California and want additional information confirming how Company does not share your personally identifiable information with third parties for their direct marketing purposes, you may contact us at [email protected] with the words “California Privacy” in the subject line of your email.

Contact Information for Complaints or Concerns: If you have any complaints or concerns about the Company or about this privacy statement, please contact:

Via email: [email protected]

Information provided by you via general e-mail inquiries to the Company such as your e-mail address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.

If you are a resident of the EU and have an unresolved data privacy concern or personal information collection, use, or disclosure concern, you may file a complaint/inquiry with us at:

Security/How Your Personally Identifiable Information Is Protected: Security for all personally identifiable information is extremely important to us. We have implemented technical, administrative and physical security measures to attempt to protect your personally identifiable information from unauthorized access and improper use. We also protect your personally identifiable information offline. Only employees who need the information to perform a specific job (for example, customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment. We continually review all such measures and update them when appropriate. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to Company, you accept that you do so at your own risk.

Your Acceptance of These Terms: By using the Site, you accept the policies and restrictions set forth in this Online Privacy Policy. If you do not agree to this policy, please do not use the Site. This Online Privacy Policy may be revised from time to time by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Online Privacy Policy to which you are bound.

Last Updated: June 20, 2020

 

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