Privacy Policy

---

PRIVACY POLICY – Smiley Wellness Coaching

www.smileywellnesscoaching.com

Effective date: July 1, 2019

Welcome to www.smileywellnesscoaching.com (the “Site”) which is owned by Smiley Wellness Coaching L.L.C. (“We”, “us”, “Smiley Wellness Coaching” and “our”) and operated from the United States. This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your PII in accordance with our website. 

Collection of Personal and Non-Personal Information (PII and Non-PII)

We collect and store certain personally identifiable information about you (i.e., information which may identify you in some way; such as your name, address, telephone number, email address, screen name and/or financial information) (“PII”) only when you voluntarily submit it. We may request that you submit PII in certain instances, such as when you purchase products and services offered by us, submit comments or questions, request information, participate in a promotion, contest or sweepstakes or utilize other features or functions of a Site. 

When you connect to our Site, there is certain technical, non-personally identifiable information which does not identify any individual (“Non-PII”) that may be collected and stored through the use of “cookie” technology and IP addresses. PII is not extracted in this process. Non-PII may include, but is not limited to, your IP host address, internet browser type, personal computer settings, and the number, duration, and character of page visits. This information assists us to update a Site so that it remains interesting to our visitors and contains content that is tailored to visitors’ interests. 

Use of Your PII. When you provide your PII at a Site, we will limit the use of the PII for the purpose for which it was collected in accordance with the terms of this Privacy Policy. Other limited uses of your PII may include:

• To respond to your questions, comments, and requests; to provide you with access to certain areas and features on a Site; and to communicate with you about your activities on a Site.
• To investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the rules or policies of a Site, or the rights of third parties; or to investigate any suspected conduct which we deem improper.
• To the extent that you provide us with financial information in connection with shopping or commercial services offered on a Site, we may use the financial information that you      provide to fulfill your order.
• To help us develop, deliver and improve our products, services, content and advertising.
• To share with our parent, subsidiary, and affiliated companies, and promotional partners involved in creating, producing, delivering, or maintaining a Site, as required to perform functions on our behalf in connection with the Site (such as administration of the Site, administration of promotions or other features on the Site, marketing, data analysis, and customer services). In order to share such information, it may be necessary for us to transmit your PII outside the jurisdiction set forth below and you agree to this transfer. Further use or disclosure of PII by these parties for other purposes is not permitted.
• For our internal purposes such as auditing, data analysis, and research to improve our products, services and customer communications.
• For other purposes as disclosed  when your PII is collected or in any additional terms and conditions applicable to a particular feature of a Site.
• For disclosures required by law, regulation, or court order.
• For the purpose of or in connection with legal proceedings or necessary for establishing, defending, or exercising legal rights.
• In an emergency to protect the health or safety of users of a Site or the general public, or in the interests of national security.

Except as provided for herein, we will not provide any of your PII to any third parties without your specific consent.

Managing Your Personal Information. You have the ultimate control over the PII that we collect and use. You can always chose not to provide certain PII, but please keep in mind that you may not be able to use some of the features offered by a Site unless you provide us with your PII (e.g., we will not be able to fulfill your purchase order without certain PII). If you wish to verify, update, or correct any of your PII collected through a Site, contact us on the details provided in the contact section of this policy.

We may also use your PII for the following purposes:

• Direct Marketing.  We may use your personal information to send you Smiley Wellness Coaching - related marketing communications as permitted by law.  You will have the ability to opt-out of our marketing and promotional communications as described in the Your Choices section below.
• For research and development.  We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. 
• To create anonymous data.  We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you.  We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
• To comply with laws and regulations.  We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. 
• For compliance, fraud prevention and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.
• With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 

Cookies

Please refer to our cookie policy to know more about how we handle cookies.

Security

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. The security on the internet is not 100% guaranteed, however we use best efforts to keep it secure for the users. We do not accept liability for unintentional disclosure. We encourage you to use caution when using the Internet.

NOTICE TO CALIFORNIA RESIDENTS - CCPA

Section effective as of: January 1, 2020

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their Personal Information, and of the rights and choices, we offer to California residents concerning that Personal Information. 

Personal information that we collect, use, and share.  We do not sell personal information.  As we explain in this Privacy Policy, we use cookies and other tracking tools to analyze website traffic and facilitate advertising.  

Your California privacy rights.  The CCPA grants California residents the following rights.  However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.
  • The categories of Personal Information that we have collected.
  • The categories of sources from  which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.

You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

How to exercise your California rights.  You may exercise your California privacy rights described above as follows:

• Right to information, access and deletion. You can request to exercise your information, access and deletion rights, by emailing  fadi.smiley@smileywellnesscoaching.com. We reserve the right to confirm your California residence to process your requests and will need to  confirm your identity to process your requests to exercise your information, access or deletion rights.  As part of this process, government identification may be required.  Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request      on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
• Request a list of third party marketers. California’s “Shine the Light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide certain information about the companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year (if any).  You can submit such a request by sending an email to fadi.smiley@smileywellnesscoaching.com with “Shine the Light” in the subject line.  The request must include your  current name, street address, city, state, and zip code and attest to the fact that you are a California resident.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

FOR EUROPEAN RESIDENTS - GDPR

We may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Smiley Wellness Coaching
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Smiley Wellness Coaching aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly      within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data. The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Smiley Wellness Coaching relied on your consent to process your      personal information.

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Sharing your personal information

We do not sell, trade, or rent Users personal identification information to others in accordance with the CCPA. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

Children

We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. 

Third party websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.

International

If you visit our Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) that by using our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.

Data Retention

We will retain your information for as long as needed to provide you the Site services, for our valid business purposes, and as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements.

Changes

Smiley Wellness Coaching has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Acceptance

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

SMILEY WELLNESS COACHING, L.L.C. 

Email: fadi.smiley@smileywellnesscoaching.com