2023

Privacy Policy

1. Introduction

This privacy notice provides you with details of how we collect and process your personal data through your use of our site llmavens.com, including any information you may provide through our site when you purchase a product or service, sign up for 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.

llMavens 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 Federal Trade Commission (FTC), the U.S. supervisory authority for data protection issues ( www.ftc.gov ). We would 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 [email protected]

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: First name, maiden name, last name, username, marital status, title, date of birth, and gender.

• Contact Data: Billing address, delivery address, email address, and telephone numbers.

• Financial Data: Bank account and payment card details.

• Transaction Data: Details about payments between us and other details of purchases made by you.

• Technical Data: 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: Username and password, purchases or orders, your interests, preferences, feedback, and survey responses.Usage Data: Information about how you use our website, products, and services.

• Marketing and Communications Data: 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 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 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 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 offenses.

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. Please see our cookie policy for further details.

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, Facebook, and Clickfunnels based outside the US;

• Advertising networks such as Facebook, Google, YouTube, Instagram, Twitter, Hotjar, and re-targeting services provided by these companies based outside the US;

• Search information providers Google based outside the US.

• Contact, Financial and Transaction Data from providers of technical, payment, and delivery services such as InfusionSoft and PayPal based outside the US.

• Identity and Contact Data from data brokers or aggregators based outside the US.

• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based outside the US.

4. How We Use Your Personal Data

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 or text message. You have the right to withdraw consent to marketing at any time by clicking on our Unsubscribe link at the bottom of our email communications or by emailing us at [email protected].

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 [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one of the following grounds has been established.

Purpose/Activity

To register you as a new customer

Type of data

(a) Identity

(b) Contact

Lawful basis for processing

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to recover debts owed to us

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise

(b) Necessary to comply with a legal obligation

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

Necessary for our legitimate interests to develop our products/services and grow our business

Marketing Communications

You will receive marketing communications from us if you have

• Requested information from us or purchased goods or services from us; or

• Provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and

• 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 following the opt-out links on any marketing message sent to you or by emailing us at [email protected] 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 [email protected].

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.

• Government bodies that require us to report processing activities.

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

We share your personal data with our approved service suppliers, some of which are outside the United States.

Countries outside of the United States do not always offer the same levels of protection to your personal data, so U.S. law has prohibited transfers of personal data outside of the U.S. unless the transfer meets certain criteria.

Many of our third-party service providers are based outside the United States, so their processing of your personal data will involve a transfer of data outside the U.S.

Whenever we transfer your personal data out of the U.S., 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 relevant authorities; or

• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by relevant authorities which give personal data the same protection it has in the United States.

Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the U.S.

7. Data Security

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.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill 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

You can see more about these rights at:

https://www.ftc.gov/about-ftc

If you wish to exercise any of the rights set out above, please email us at [email protected].

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 several 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.

11. 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.

What is a Cookie?

A "cookie" is a piece of information that is stored on your computer's hard drive and records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyze traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system.

If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

How do we use cookies?

We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards to how you are using our website. This helps us to develop and improve our website as well as products and/or services in response to what you might need or want.

Cookies are either:

• Session cookies: These are only stored on your computer during your web session and are automatically deleted when you close your browser. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any personal data from your computer.

• Persistent cookies: A persistent cookie is stored as a file on your computer and remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. [We use persistent cookies for Google Analytics.] [We also use Facebook Pixels]

Cookies can also be categorized as follows:

• Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and/or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

• Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources, and see which parts of the site are most popular.

• Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.

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