- Describing the new rights available to Michigan consumers under the Michigan Consumer Privacy Act
- Clarifying how personal information is shared for advertising related activities
Your privacy is very important to us.
What Type of Information Do We Collect?
We may collect the following categories of personal information, although, not all categories may be collected for every individual because it may depend on whether you are a visitor to our websites or you purchase a product or service or pay a monthly fee for our services:
- Personal identifiers, such as your name and mailing address
- Device and online identifiers and related information, such as your telephone number and email address
- Internet, application, and network activity, such as cookie IDs and browser visits
- Government identifiers, such as national identification numbers and driver’s license numbers
- Demographic information, such as age and date of birth
- Financial information, such as credit and debit card numbers, bank accounts, retirement accounts, investments, etc.
- Characteristics of protected classifications under state or federal law, such as gender and nationality
- Purchase history information, such as products and services you have purchased and/or returned
- Location information, such as geo-location information
- Audio, visual, and other sensory information, such as audio and video recordings
- Employment information, such as occupation, title, licenses and professional memberships
- Background and criminal information
- Education information, such as degrees and schooling information
- Individual preferences and characteristics, such as inferences related to purchase patterns and preferred learning methods
- Behavioral information, such and when and how often you access our learning and educational resources, and how often you communicate with us.
How Do We Collect Information?
We collect information about you in a few different ways:
- We collect information directly from you when you share information with us; for example, when you register for and/or attend a live event or webinar or training, fill out a survey, complete paperwork or online forms, make a purchase, create an account, post a review or comment on one of our social media pages, post user-generated content on one of our or third party websites or mobile services, participate in a contest or sweepstake or promotion, or request customer service or contact us with an inquiry or request;
- We collect information indirectly and passively from you through technology, such as through a cookie placed on your computer when you visit our websites or from the device or browser you use to access our services (see more below).
- We also collect information from third parties and other sources to help us correct or supplement our own records, improve the quality or personalization of our services and marketing, and to prevent or detect fraud. For example, we belong to ad networks that may use your browsing history across participating websites and mobile services to show you interest-based advertisements, and you may also see our ads for WeEmpowerUAcademy, LLC, on participating websites and mobile services based on how you browse.
We reserve the right to combine personal information collected from any and all sources. Our goal is to only collect the information that is needed to support our business.
Device Information: We collect technical information when you visit our websites or use our mobile applications or services. This includes information such as Internet Protocol (IP) address, the type of mobile device you use, your device operating system and browser type, a unique device identifier, the address of referring websites, the path you take through our websites, pages visited, average time spent on our websites, and other information about your session on our websites.
- Precise Device Location: We may collect information about your location when your device is set to provide location information. For example, your device’s GPS signal may allow us to determine which of our live events is closest to you.
Browsing Information: We use our own and third-party technologies such as cookies, web beacons, and mobile device identifiers to collect information about the use of our websites and mobile services. We use these tools to provide an integrated and more personalized customer experience for you. For example, a cookie, which is a small data file that can be placed on your hard drive when you visit certain websites, allows us to provide you relevant information as you use or return to our sites; web beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our websites and other sites were effective. We also use tracking pixels (i.e. Google Analytics) to aid in measuring and tracking where our website traffic is coming from and to track the performance of our site. Finally, we use remarking pixels from Facebook and Google to aid in customized, targeted follow-up advertising.
Under certain circumstances, we permit third parties to collect information on our websites for their own business purposes using cookies, web beacons, iframes, and similar technologies. To learn more about cookies, including information on what cookies have been set on your computer and how cookies can be managed and deleted, visit https://www.ftc.gov/site-information/privacy-policy/internet-cookies.
Do Not Track Disclosure: We do not respond to “Do Not Track” signals.
How We May Use Personal Information
We may use your Personal Information to provide you products and services, such as to fulfill your requests for educational services or to help us personalize our services and marketing to you. We also use your Personal Information to support our business functions, such as fraud prevention, marketing (i.e., for affiliates to offer complementary services), and legal functions.
Some examples include:
- To fulfill your purchase or requests for services and provide customer service
- To create and maintain your account
- To conduct auditing and monitoring of engagement
- To conduct marketing, personalization, and third-party advertising through our family of companies and affiliates
- To protect the security and integrity of our websites, mobile services and our business, and help prevent fraud
- To update our operational and technical functionality
- To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
- To conduct research and development
- To fulfill our legal function or obligations
To do the above, we combine Personal Information and non-personal information, collected online and offline, including information from third-party sources. We also may transfer or share your personal information for these purposes within our corporate family of companies and affiliates, as permitted by law.
How Do We Share Your Personal Information Outside of WeEmpowerUAcademy, LLC?
All of the categories of Personal Information that we collect have been shared for business purposess with our family of companies and affiliates. We do not sell or rent your personal information for monetary consideration; however, we may receive an affiliate referral fee if you purchase a product or service from an affiliate company. We may share your Personal Information in other circumstances, such as in order to conduct our business, for other companies to offer you complementary products and services, in the event all or a part of our business is merged, sold, or reorganized, when legally required, as described below, or with your consent.
We will not share your personal information outside of our corporate family of companies and affiliates, except in the following circumstances:
We share personal information about you with service providers that help with our business activities, including shipping vendors, payment card processors, marketing and advertising vendors, and companies that help us improve our products and services. Your personal information may be stored and processed by our service providers in the United States or other locations where the service providers or WeEmpowerUAcademy, LLC, maintain facilities.
Products and Services Offered by Other Businesses
We will sometimes enable other businesses and affiliates to make their products or services available to our customers. You may purchase these companies’ products or services from our team members or directly from the other businesses. When you purchase these products or services, we identify the other business and share with this business personal information related to your purchase of their products and services.
Co-Branded Products and Services
We may share your personal information with affiliate companies that offer complimentary and/or co-branded products or services, and we may receive compensation from these affiliate companies when you make a purchase. We instruct these companies to not use your personal information for purposes other than offering you their complementary products and administering your use of their services.
Legal Requirements and Protection of Our Company and Others
We may share your Personal Information in other special circumstances, which include situations when sharing is required by law, or we believe sharing will help to protect the safety, property, or rights of WeEmpowerUAcademy, LLC, our customers, our team members, or other persons. Examples include:
- Protecting our intellectual property
- Identifying and addressing fraud or financial risk
- Providing personal information to law enforcement at their written request
- Responding to a subpoena or other valid legal inquiry
- Responding to an investigative body in the case of a breach of an agreement or violation of law.
In the event that all or a part of our business is merged, sold, or reorganized (including transfers made as a part of insolvency or bankruptcy proceedings), personal information about you could be shared with the successor business. We will use reasonable measures to recommend that any successor treats your information in accordance with this Policy.
Advertising Related Activities
We may share aggregated or pseudonymous information (pseudonymous information includes things like a device identifier, type of device, IP addresses, cookies, and other information associated with your browsing and app usage) with other companies, such as publishers, advertisers, measurement analytics providers, and others. We do not share information that directly identifies you (information such as name or email address) with these companies.
Advertisers and partners may also use their own cookies. We do not control the use of these cookies and expressly disclaim responsibility for information collected through them.
With Your Consent
In circumstances other than those described above, we will ask for your affirmative consent before we share your personal information outside of our corporate family of companies and affiliates.
How Can You Make Choices About Receiving Marketing, Promotional, and Other Information?
WeEmpowerUAcademy, LLC, may send you marketing, promotional or other information. In certain cases, when interacting with us, you may be provided with a choice to opt-in or opt-out of receiving such information. In other cases, you will not be presented with this choice. If you, at any time, choose to opt-out of receiving such information, we will abide by that marketing preference. Moreover, at any time (no matter what you have chosen or informed us of in the past), you may send us an email to JW@WeEmpowerUAcademy.com to update your marketing preference or to request that we delete your personal information; we will abide by that preference and update your personal information accordingly. We will respond to your requests regarding your personal information within 30 days. You may of course also follow the unsubscribe instructions contained in the marketing communications you receive from us.
Some of our mobile services use your device’s location information. You may be able to adjust the settings of your mobile device at any time to control whether your device communicates this location information. We may also offer additional controls on our use of your mobile location information.
Kindly note that no matter what your marketing preferences are, we may contact you to acknowledge, confirm or fulfill any order that you place, to respond to you, or for other legitimate business reasons.
When we are sending marketing communications to you, we use the following standards:
- We use an opt-in standard for automated phone and text messages. Opt-in means we will only conduct the activity with your affirmative consent.
- We use an opt-out standard for email, app notifications, postal mail, and for sharing personal information with our affiliates and any companies outside our corporate family of companies for their use in direct marketing of their products and services. Opt-out means we or they may contact you, but will stop upon your request (as described below).
If you contact us by email or mail, please be sure to include your full name, the types of communications you would like to receive or not receive, and your related contact information. For instance, if you would like to opt out of mail, include your mailing address. Please allow sufficient time for your marketing preferences to be processed. It may take up to 30 days to process your requests. Please note that postal mailings are often prepared many weeks in advance, and you may continue to receive mail for six to ten weeks.
Please know that, even if you opted out of receiving marketing communications from us, we may still contact you for transactional or informational purposes. Some examples are contacts for customer service or event reminder notices. We may also need to contact you with questions or information regarding your purchase.
How Do You Access and Update Your Personal Information?
We provide you with various ways to access or update your personal information, including contact and account information. We also take reasonable steps to keep your personal information accurate and complete.
You can access or update your personal information, including contact or account information, in the following ways:
- If you have created an account on one of our websites or mobile services, log into your account. Once you do, you will be able to enter and update your own contact information and payment information, as well as contact information for recipients you have designated.
- If you need to access your personal information related to a specified service provided to you by a WeEmpowerUAcademy, LLC, service provider or business partner or affiliate, we will refer you to the service provider or business partner or affiliate.
If you are a resident, please refer to the “What Are Your California Privacy Rights?” section for additional information on your rights under the Michigan Consumer Privacy Act.
How Do We Secure Your Personal Information?
We recognize the importance of maintaining the security of our customers’ personal information. We use reasonable security measures, including physical, administrative, and technical safeguards to protect your personal information.
We have team members who are responsible for helping to protect the security of your information. Whether you are on our websites, our mobile services, or at our live events, we use reasonable security measures, including physical, administrative, and technical safeguards. These measures may include physical and technical security access controls or other safeguards, information security technologies and policies, procedures to help ensure the appropriate disposal of information, and training programs.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or services, you are responsible for keeping this password confidential. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your Personal Information transmitted to our websites.
How Does WeEmpowerUAcademy, LLC Protect the Privacy of Children Online?
The Website is not designed to solicit information from individuals under the age of 16. We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or legal guardian and believe we may have inadvertently collected personal information from your child, please contact us at: JW@WeEmpowerUAcademy.com.
Your Michigan Privacy Rights
Shine the Light Disclosure
Under Michigan “Shine the Light” Act, if you reside in Michigan and have an established business relationship with us, you have the right to receive information about our sharing of your personal information with affiliated entities or non-affiliated third parties for direct marketing purposes. If you wish to exercise these rights, please send your written request, via email or postal mail to “Shine the Light Disclosure” in the subject line. Please include your full name, street address, city, state, and zip code in the body of your request. Our contact information is:
Attn: Privacy and Legal Department
2785 E. Grand Blvd
Detroit, MI 48211
We will not accept requests via the telephone or facsimile. We also may not be able to respond to requests that are not labeled or sent properly or do not have complete information.
Do Not Track Disclosure
We do not collect or respond to Do Not Track signals and our websites do not function differently based on any Do Not Track preferences that may be received. For more information on Do Not Track signals, please visit https://allaboutdnt.com/
Michigan Consumer Privacy Act
The Michigan Consumer Privacy Act affords Michigan consumers certain rights over their personal information (subject to certain exceptions). If you are a Michigan resident, please review our Michigan Consumer Privacy Act Notice for information on your rights under Michigan law.
How Will I Know if This Policy Changes?