1. INTRODUCTION

From Anxiety to Calm, Inc. is committed to respecting your privacy choices and being transparent about what information we collect from you and how we use that information. We do not share, sell, license, trade, or read your personal information to others except in the ways explained in this privacy policy.

The purpose of this privacy policy is to help you understand:

• Why we collect personally identifiable information;
• What personally identifiable information we collect;
• How we use that information, including how the information is stored and whether we share the information with third parties; and
• Your choices regarding our collection, use and distribution of your information

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.sharyndiubaldo.com, including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.

By providing us with your data, you warrant to us that you are over 13 years of age.

From Anxiety to Calm, Inc. is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner of Canada’s office, the Canadian supervisory authority for data protection issues (https://www.oic-ci.gc.ca/en). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@sharyndiubaldo.com.

YOUR CONSENT TO THIS PRIVACY POLICY

By using this website you consent to the terms of this Privacy Policy.

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymized data.

We may process certain types of personal data about you as follows:

• Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including: 

• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
• order our products or services;
• create an account on our site;
• subscribe to our service or publications;
• request resources or marketing be sent to you;
• enter a competition, prize draw, promotion or survey; or
• give us feedback.
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
  • analytics providers [such as Google] based outside of Canada;
  • advertising networks [such as [Facebook] based outside of Canada]; and

Identity and Contact Data from publicly availably sources such as Elections Canada.

4. HOW WE USE YOUR PERSONAL DATA

Non-personally identifiable information

We may use non-personally identifiable information, like data about the most visited site pages or the duration of certain site page visits that are not tied to a specific site user, to maintain, improve, and protect our site and our product and service offerings.

Personally identifiable information

When you sign up for our newsletter, we use the name and email address that you provided to subscribe to our newsletter and/or our email list. We will send you periodic newsletters and/or emails. We store the name and email address that you provided in an SSL encrypted database.

When you purchase a digital product or our services we use the personal information you provide to process the transaction and deliver your digital product and/or service, and to provide you customer service as necessary. We store this information in an SSL encrypted database.

We will only use your personal data when legally permitted. The most common uses of your personal data are: 

• Where we need to perform the contract between us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by emailing us at info@sharyndiubaldo.com.

Purposes for processing your personal data  

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at info@sharyndiubaldo.com. if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing communications 

 You will receive marketing communications from us if you have:

1. Requested information from us or purchased goods or services from us; or
2. If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; or when you entered a competition or registered for a promotion or free resources; and
3. In each case, you have not opted out of receiving that marketing. 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences] OR [by following the opt-out links on any marketing message sent to you or] OR by emailing us at info@sharyndiubaldo.com. at any time].

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at info@sharyndiubaldo.com.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Canada Revenue Agency and other authorities based in the Canada and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Please email us at info@sharyndiubaldo.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

The security of your personally identifiable information is extremely important to From Anxiety to Calm, Inc. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. 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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We use bucket.io, Kartra, PayPal and Stripe to process your purchases of our products and services. Your information is stored in an SSL encrypted database.

Be sure to keep in mind that no method of transmission over the Internet or method of electronic or physical server storage is 100% secure. While we value the privacy and security of your personal information, we cannot guarantee against or prevent potential security breaches, nor can we assure you that the personally identifiable information that you provide us will never be disclosed in a manner inconsistent with this privacy policy.

If you have any reason to believe that the security of your information has been compromised in any way, please email us immediately at info@sharyndiubaldo.com.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please email us at info@sharyndiubaldo.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally 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.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Except in situations previously described, we will not sell or give any personally identifiable information to any third parties.

We may however be required by law enforcement or judicial authority to provide personally identifiable information to the appropriate governmental authorities. If requested by law-enforcement or judicial authorities, we will provide this information on receipt of the appropriate documentation. We may also release information to law-enforcement agencies or other third parties if we feel it is necessary to protect the safety and welfare of our personnel or to enforce our Terms and Conditions.

11. COOKIES

Cookies are small data files, typically made up of a string of text, that assign you a unique identifier. This information enables our website to receive information from your computer to provide a more tailored and user-friendly experience for you.  For example, if you login to our site we may be able to personalize your experience by recognizing your name when you return to the site, save your login and your password, or enable a shopping cart. Our newsletters may use cookies to measure the effectiveness of our marketing efforts (for example, tracking the clicks on the links in our emails and newsletters) or we may use cookies to determine the number of times website visitors have accessed a particular area or page on the website. Most web browsers have a function that allows you to delete existing cookies on your device or you can set your browser option so that your device does not receive or accept cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

12. COMMUNITY FORUM (FACEBOOK GROUP)

Our website may offer a publicly accessible community forum. You should be aware that any information you provide in this area may be read, collected, and used by others who access them. To request removal of your personal information from our community forum, you may email us at info@sharyndiubaldo.com. We may or 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.

Does this website comply with the Children’s Online Privacy Protection Act?

Yes. We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 18 years of age. Our website, products and services are all directed to people who are at least 18 years old or older.

13. OPT-OUT

If it anytime you do not wish to receive offers or emails from us, you must tell us in order for the communications to stop.  You may do this by either clicking the unsubscribe link located at the bottom of our emails or you may contact us directly by sending an email to info@sharyndiubaldo.com.

14. RIGHT OF ACCESS

As per GDPR Article 15, you have the right to request access to your personal data and all information about how this personal data is being processed and used by From Anxiety to Calm, Inc.

If you wish to access the data we have on you, please contact us at info@sharyndiubaldo.com with the subject line: GDPR Data Request.

15. RIGHT TO ERASURE

As per GDPR Article 17, you have the the right to request erasure of personal data related to you under certain circumstances.

If you wish to have the data we have on you removed, please contact us at info@sharyndiubaldo.com with the subject line: GDPR Erasure Request, along with the grounds on which your data should be removed.

16. COMMUNICATION AND TESTIMONIALS

All written and verbal communication communicated to the company (From Anxiety to Calm, Inc.) and/or its staff is the company’s property, including email communication, phone communication, social media communication (Facebook, Instagram, Twitter, LinkedIn), written and/or verbal testimonials given, etc. and this gives the company and its staff the right to use however it/they see fit (for example, on its website, social media pages (Facebook, Instagram, Twitter, LinkedIn), or in conversation with others). Please note: If your communication is used by us in any way (such as in the situations mentioned above), we will only use your first name and region you live in as a reference for where this communication came from.

17. NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY

We may change our privacy policy from time to time without notice. If we make a material change to this policy, we will post the changes on this privacy policy webpage and may also inform you of the changes by other means such as our newsletter or in a direct email containing the update.

18. QUESTIONS

If you have any questions about this Privacy Policy or Terms and Conditions, please contact us at info@sharyndiubaldo.com.

Please read our Disclaimer and Terms and Conditions.