Privacy Policy

TABLE OF CONTENTS

• About This Privacy Notice
• Personal Information We Collect
• Purpose and Legal Basis of the Processing
• How Long We Keep Your Personal Information
• How We Share Your Data
• Your Choices and Rights
• How We Protect Your Data
• Personal Data Protection Authority
• How to Contact Us
• Changes to This Privacy Notice

ABOUT THIS PRIVACY NOTICE

This Policy explains how INFINITY SQUARED MEDIA LLC, UIC 0801201782 (referred to as “We”, “Us” or “Our”) processes your personal data. “Personal Information” or “Personal data” means any information that allows someone to identify, or reasonably link to, you directly or indirectly. When we describe “processing” of Personal Information, we mean how we collect, use, share, and retain Personal Information.

PERSONAL INFORMATION WE COLLECT

We process the personal data of the following data subject categories:

• CustomerCustomers are all individuals who are using our services.
• Email SubscriberEmail Subscribers are all individuals who have subscribed to receive emails from us.
• Social Media UserSocial Media Users are all individuals interacting with us in any way on social media, such as YouTube, Instagram, Facebook, etc.
• Website VisitorWebsite visitors are all individuals visiting our website.

We process the following categories of personal data:

• Business Intelligence dataAnonymized IP address, website sessions, duration of sessions, visited links, User Agent, etc.; We process analytical data about the user experience on our Website and while using our Service.Data collection:
  • Automatically collected data
  We aren’t receiving personal data from third parties.
• ContentIn general, no personal data is included in our content. However, sometimes our content may contain personal data. In those cases, we will use personal data only where there is a legal basis for the processing; Personal data may be processed in our content, such as blog posts, videos, podcasts, etc.Data collection:
  • Directly from the Data Subject
  We aren’t receiving personal data from third parties.
• Customer NotesThe information includes goals, habits and any other notes and information provided by the customer; We provide the option for our customers to make personal notes on our Online Courses. Customers can delete the information at any time or decide not to provide it altogether.Data collection:
  • Directly from the Data Subject
  We aren’t receiving personal data from third parties.
• Customer support dataEmail, name and support ticket information; We process data to provide customer support for our services.Data collection:
  • Directly from the Data Subject
  We aren’t receiving personal data from third parties.
• Email Subscriber’s dataThe data includes the email address and any other information provided by the email subscriber; The personal data is collected with the purpose to send emails to subscribers. Email subscribers can unsubscribe at anytime using the “unsubscribe” button.Data collection:
  • Directly from the Data Subject
  We aren’t receiving personal data from third parties.
• Identification dataThe data may include names and email; Identification data is processed to identify the data subject and/or to enter into a contract.Data collection:
  • Directly from the Data Subject
  We aren’t receiving personal data from third parties.
• Payment informationThe data includes the due or completed payment amount, date of payment and payer, purchase ID; The personal data is collected to track due and completed payments and to be able to make payments.Data collection:
  • Directly from the Data Subject
  • Data received from a third party
  We receive personal data from:
  • Payment Service Providers
• Sensitive dataThe sensitive data includes information regarding mental health, racial or ethnic origin, political opinions, religious or philosophical beliefs, person’s sex life or sexual orientation; Sensitive data is processed solely with the explicit consent of the data subjects willing to share their personal stories, advice or breakthroughs with us and the other members of the community such as the other email subscribers.Art. 9 paragraph 1 doesn’t apply because the data subject has given explicit consent to the processing of those personal data for one or more specified purposes; Data subjects are not required to share any sensitive information and do so on an opt-in basis. Data subjects may opt out at any time and request the deletion of the data. Information already shared with the email subscribers cannot be deleted from their mailboxes by us.Data collection:
  • Directly from the Data Subject
  We aren’t receiving personal data from third parties.
• Social Media InteractionsThe data includes the user’s public profile information, exchanged direct messages, likes and comments; The purpose of the processing is to maintain a social media presence and interact with other social media users. All social media users are free to like or unlike posts, make or delete comments and generally use all features provided by the social media developer.Data collection:
  • Data collected from public sources
  • Directly from the Data Subject
  • Data received from a third party
  We receive personal data from:
  • Social Media Service Providers
• Survey dataWe may collect different information considering the purpose of the survey. Where possible and appropriate we try to anonymize the survey; We process personal data to gather feedback for our services and hear opinions on different topics. Data subjects can decide not to participate in our surveys and/or request the deletion of gathered information.Data collection:
  • Directly from the Data Subject
  We aren’t receiving personal data from third parties.
• Website behavior dataThe data includes visited pages, anonymized IP addresses and session durations; The personal data is collected with the purpose to track the behavior of the visitors on the website and help us improve the user experience.Data collection:
  • Automatically collected data
  We aren’t receiving personal data from third parties.
• Website performance dataData includes an anonymized IP address to be able to redirect you to the nearest server to your location and thus make the website load much faster; We collect data to improve the performance of our website and services.Data collection:
  • Automatically collected data
  We aren’t receiving personal data from third parties.

PURPOSE AND LEGAL BASIS OF THE PROCESSING

This Privacy Notice covers the following services:

• Premium SubscriptionOur Premium Subscription includes all self-development educational resources on our website and apps, such as Emotional Mastery, Resilience, Healthy Relationships and others (referred to as “Premium Subscription”). Website: https://markmanson.net/subscribe; The Service is available as iOS, Android, Web application. More information about the service and the terms of use at https://markmanson.net/terms-and-conditions

We process your personal data for the following purposes:

• Business IntelligenceLegal basis:
  • Consent
  Processed personal data categories:
  • Website behavior data
• Email MarketingLegal basis:
  • Consent
  Processed personal data categories:
  • Email Subscriber’s data
• Personalized AdvertisementLegal basis:
  • Consent
  Processed personal data categories:
  • Business Intelligence data
  • Website behavior data
• Providing Online CoursesLegal basis:
  • Performance of a contract
  Personal data is processed for the provision of the following services:
  • Premium Subscription
  Processed personal data categories:
  • Customer Notes
  • Customer support data
  • Identification data
  • Payment information
  • Website performance data
• Social Media PresenceLegal basis:
  • Consent
  Processed personal data categories:
  • Social Media Interactions
• The Breakthrough NewsletterLegal basis:
  • Consent
  Processed personal data categories:
  • Email Subscriber’s data
  • Sensitive data

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep your personal data only as long as necessary to achieve the purpose it is processed for. The full list of the purposes for which we process personal data can be found above.

We determine the appropriate retention period for personal information on the basis of the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

Here are some of the categories of our retention periods:

• Automatic expiration after a period of timeWe have set certain retention periods so that some data expires automatically after a specific period of time.
• Data BackupsWe back up data for security reasons. Sometimes it is impossible to delete the data stored in a backup immediately. In such cases, we will securely store your personal information and isolate it from any further processing until deletion is possible.
• Data obtained during pre-contractual relationsWe process data when the processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.
• Deletion of the data by the data subjectData subjects can delete the data by themselves. In this case, the data is retained for a short period of time after the deletion so the data subject could be able to revert a deletion by mistake.
• Establishment, exercise or defense of legal claimsWe may retain information where necessary for the establishment, exercise or defense of legal claims.
• Retention of pseudonymized dataIn some cases we pseudonymize the data and store it for a longer period of time.
• Retention or deletion under a contractual obligationWe may be subject to a contractual obligation to keep or delete the data. In such cases we may retain or remove the information to comply with our contractual obligations.
• Retention or deletion under a legal obligationWe may be subject to a legal obligation to keep or delete the data. Examples include mandatory data retention laws, government orders to preserve data relevant to an investigation or data kept for the purposes of litigation. Conversely, we will remove unlawful content if the law requires us to do so.
• Upon Request for RemovalWe delete the personal data upon a request for removal from the data subject when there is no other legal ground for the retention of the data.

After expiration of the applicable retention periods, we will either delete or anonymize your personal information.

HOW WE SHARE YOUR DATA

We share personal data with the following third parties:

• Accounting Service ProvidersWe may share personal data with Accounting Service Providers to fulfill our legal obligations to maintain diligent accounting and comply with legal and tax requirements.Shared personal data categories:
  • Payment information
  • Employee Payroll Information
• Ad Service ProvidersWe share information with Ad Service Providers so they can serve ads to the most relevant audience who is interested in our services.Shared personal data categories:
  • Website behavior data
• Analytics Service ProvidersWe share information with Analytics Service Providers to be able to analyze the data we have collected.Shared personal data categories:
  • Website behavior data
  • Business Intelligence data
  • Website performance data
• Cloud Infrastructure Service ProvidersWe share data with cloud infrastructure service providers to be able to provide our services and maintain our operations.Shared personal data categories:
  • Identification data
  • Payment information
  • Sensitive data
  • Customer Notes
  • Survey data
  • Customer support data
• Cloud-based Storage Service ProvidersWe may share data with Cloud-based Storage Service Providers to store and edit files and media.Shared personal data categories:
  • Identification data
• Communication Service ProvidersWe share information with Communication Service Providers to be able to coordinate our team operations.Shared personal data categories:
  • Customer support data
• Copyright Protection Service ProvidersWe may share data with Copyright Protection Service Providers to help us protect our copyrights and scan the internet for copyright infringements.Shared personal data categories:
  • Content
• Email Marketing Service ProvidersWe share information with Email Marketing Service Providers to be able to send emails and newsletters.Shared personal data categories:
  • Identification data
  • Sensitive data
  • Email Subscriber’s data
• Fraud Prevention and Cybersecurity Service ProvidersWe may share data with Fraud Prevention and Cybersecurity Service Providers to help us secure our website and app and prevent any fraudulent behavior.Shared personal data categories:
  • Website behavior data
  • Website performance data
• Payment Service ProvidersWe may use Payment Service Providers to be able to receive and make payments.Shared personal data categories:
  • Payment information
• Project Management Service ProvidersWe may use project management service providers to organize our internal operations, products, and projects.Shared personal data categories:
  • Job Candidates Application
• Software DevelopersWe share information with software developers when this is necessary for the development of our services.Shared personal data categories:
  • Business Intelligence data
  • Identification data
  • Payment information
• Third Party ContractorsWe hire Third Party Contractors to help us create, edit and manage our content (videos, blog posts, newsletters, etc) across all platforms, optimize it for search engines and social media, analyze our performance and create business strategies.Shared personal data categories:
  • Website behavior data
  • Business Intelligence data
  • Identification data
  • Payment information
  • Sensitive data
  • Email Subscriber’s data
  • Customer Notes
  • Survey data
  • Customer support data
  • Website performance data
  • Social Media Interactions
  • Job Candidates Application
• Website Performance Service ProvidersWe may share data with Website Performance Service Providers to improve the performance of our website and services.Shared personal data categories:
  • Website performance data

YOUR CHOICES AND RIGHTS

Here are your rights as a data subject:

• Be informedBe informed of the personal data we process about you and how we process it.We inform you:
  • through this Policy
  • through information provided to you as you use our Service
  • by answering your specific questions and requests when you contact us
• Know/AccessRequest to know and access the personal data we process about you.To request a copy of your personal data you can contact us at support@markmanson.net
• CorrectionRequest that we amend or update your personal data where it’s inaccurate or incomplete.You can edit your User Data by contacting us at support@markmanson.net or by using your user profile if you have a Premium Subscription account.
• DeletionRequest that we delete certain of your personal data.For example, you can ask us to delete your personal data:
  • that we no longer need for the purpose it was collected for
  • that we process based on the legal basis of consent, and you withdraw your consent
  • when you object (see section ‘Object’ below) and
  • you make a justified objection, or
  • you object to direct marketing
  There are situations where We are unable to delete your data, for example when:
  • it’s still necessary to process the data for the purpose we collected it for
  • Our interest in using the data overrides your interest in having it deleted. For example, where we need the data to protect our services from fraud
  • We have a legal obligation to keep the data, or
  • We need the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account
  To delete your personal data you can contact us at support@markmanson.net. You can also see more details in the section “HOW LONG WE KEEP YOUR PERSONAL INFORMATION”.
• RestrictionRequest that we stop processing all or some of your personal data.You can do this if:
  • your personal data is inaccurate
  • our processing is unlawful
  • we do not need your information for a specific purpose, or
  • you object to our processing and we are assessing your objection request. See section ‘Object’ below.
  You can request that we stop this processing temporarily or permanently.You can exercise your right to restriction by contacting us at support@markmanson.net.
• ObjectObject to us processing your personal data.You can do this if:
  • We are processing your personal data on the legal basis of legitimate interests, or
  • We are processing your personal data for tailored advertising.
  To exercise your right to object, you can contact us at support@markmanson.net.
• Data portabilityRequest a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.You can request us to transmit your data when we are processing your personal data on the legal bases of consent or performance of a contract. We will try to honor any request to the extent possible.For information about how to exercise the right to portability, see ‘Access’ above.
• Not be subject to automated decision makingNot be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.We don’t perform automated decision making including profiling.
• Withdrawal of consentWithdraw your consent to us collecting or using your personal data.You can do this if We are processing your personal data on the legal basis of consent.To withdraw your consent, you can:
  • adjust the relevant control
  • contact us at support@markmanson.net
• Lodge a complaint with a supervisory authorityYou have the right to lodge a complaint with a supervisory authority if you believe any of your rights have been violated.See the contact details of the data protection authorities here.

HOW WE PROTECT YOUR DATA

We take the privacy and security of your Personal Information, including information considered sensitive, seriously. Our cybersecurity team actively works to maintain the integrity, confidentiality and availability of our Services and our policies and protocols are focused on protecting your Personal Information. We consistently strive to improve our defenses in the ongoing battle against threat actors. That said, no method of transmission over the Internet, or method of electronic storage, is fully secure, and We cannot guarantee the security of your Personal Information. Our security, safety, and privacy features are provided on an “as-is” basis. As such, their effectiveness and error-free operation cannot be guaranteed, and we cannot ensure absolute confidentiality, anonymity, or personal safety.

In the event that we are required by law to inform you of any unauthorized access to your Personal Information, we may notify you electronically or in writing in accordance with applicable law.

PERSONAL DATA PROTECTION AUTHORITY

Authority: Autoriteit Persoonsgegevens

Phone number: 0031 70 888 8500

Email: info@autoriteitpersoonsgegevens.nl

Address: Prins Clauslaan 60, P.O. Box 933742509, AJ Den Haag/The Hague, Netherlands

Website: https://autoriteitpersoonsgegevens.nl

You can find a full list of the Data Protection Authorities under GDPR here.

HOW TO CONTACT US

We welcome your comments, questions, or complaints regarding this Privacy Notice, our use of your Personal Information, or our response to your requests regarding your Personal Information. Please contact us using the following contact information:

• Support CenterOur Support center will help you with any request you have regarding your personal data. Contact us at: support@markmanson.net

CHANGES TO THIS PRIVACY NOTICE

The latest version of the policy will govern our use of your Personal Information. We may revise this policy from time to time. If we determine, in our sole discretion, that the changes we make to this policy are material, we will notify you in advance.

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