Privacy Policy
We understand that privacy and the security of your personal information is extremely important. This policy sets out what we do with your information and what we do to keep it secure. It also explains where and how we collect your personal information, as well as your rights over any personal information we hold about you. This Policy explains how we do this and tells you about your privacy rights and how the law protects you.
Introduction
Last updated on November 26, 2023.
We may change this privacy notice from time to time–when we do, we will inform you via the Site Privacy Policy via a banner or pop-up notice, sending out an email update or creating a blog or news post.
Please carefully read the following Privacy Policy of Seva Life Practice, LLC and all of its subsidiaries, successors in interest, and assigns (collectively, “Seva Life Practice, LLC”, “us”, “we”) before using: theshiftin.com, practice.theshiftin.com all related websites, products, services and related mobile applications (the “Services”), (collectively, the “Site”). By using the Website you consent to this Privacy Policy. This means that you accept, agree to be bound, and abide by the Privacy Policy. If you do not agree to the Privacy Policy cease use of this Website immediately.
Your privacy is very important to us. Our Privacy Policy spells out Seva Life Practice, LLC’s commitment to respecting the privacy of the members and visitors to our Site. We reserve the right to change this policy at any time, which we'll do through online posting or an email message sent directly to you. We are very careful with what we do with your information.
This Privacy Policy governs your access to and use of theshiftin.com, including any content, functionality and services offered on or through this Website whether as a guest or a registered user. This Privacy Policy also describes how Seva Life Practice, LLC collects and uses the personal information you provide to us on our Site. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
Collection and Use of Personal Information
We collect personal information from you to provide an efficient, meaningful and customized experience for you on the Site.
We collect the following personal information from you:
- Contact Information such as name, email address, mailing address and phone number
- Billing Information such as credit card number and billing address
- Unique Identifiers such as user name, account number and password
As is true of most websites, we automatically gather information about your computer such as:
Your IP address, time and date of visit, browser type, referring/exit pages, operating system, agent version, platform, SDK version, timestamp, API key (identifier for application), application version, device identifier, iOS Identifier for Advertising, iOS Identifier for Vendors, Media Access Control (MAC) address, International Mobile Equipment Identity (IMEI), Model, manufacture and OS version of device, session start/stop time, locale (specific location where a given language is spoken), time zone, and network status (WiFi, etc.).
We may log this information for: system administration and improvement, order verification, marketing and system troubleshooting purposes.
We use this information to:
- Fulfill your order
- Send you an order confirmation Administer your account
- Send you a newsletter
- Send you marketing and promotional communications
- Respond to your questions and concerns
- Improve our website and marketing efforts
- Conduct research and analysis
- Display content based upon your interests
What Data Do We Collect About you
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may collect and process your personal data in different ways:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us.
Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. This may include product, content, files, courses, quizzes, surveys or any other content you upload to or create on the Website.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you.
Other Information Collected
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this : Cookie Policy.
Sensitive Data
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 contacting us using the contact us form on the Website or using the privacy settings in your profile. 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.
Communication Data : We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data: We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data:We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data: We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data: We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Marketing communications
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if you made a purchase or asked for information from us about our goods or services or you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent. 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 by emailing us via the contact us form at any time. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc
Disclosures of your Personal Data
We may have to share your personal data with the parties set out below:
Online Course platform provider Zenler.com who will be data processor of your data. We have entered into a data processing addendum with Zenler to process your data. Other companies in our group who provide IT and system administration services and undertake leadership reporting. Service providers who provide cloud infrastructure, video hosting, live video platforms, email provider, IT and system administration services.
- Amazon
- Sendgrid
- FileStack
- Vimeo
- Zoom
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.
International transfers
We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA). 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: Our Online course platform Zenler provider based in the UK is our data processor and we have entered into data processing agreement for the processor to protect your personal data. 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. Where we use providers based in the United States (for example Amazon, Sendgrid) we may transfer data to them where we have signed data processing addendums for the provider to provide protection of 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. Please email us at support@zenler.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.
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. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
How Do We Protect Your Information and Secure Information Transmissions?
We employ commercially reasonable methods to ensure the security of the information you provide to us and the information we collect automatically. This includes using standard security protocols and working only with reputable third-party vendors.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
Email is not recognized as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL.
Information Sharing
We will share your personal information with third parties only in the ways that are described in this privacy statement. We may share personal information with certain third parties in the U.S. that perform services on our behalf. The services provided by those third parties may include: operating the website, hosting the website, providing the products and services you request, authorization and processing of your payments, serving advertisements to you, marketing and promotional material distribution (including direct mail marketing). Those third parties are not authorized to use or disclose personal information you provide to us on or through this website for any purpose other than to perform the services designated by us.
We and our third party service providers in the U.S. may also disclose your personal information:
- As required or permitted by law such as to comply with a subpoena, in response to a search warrant or other legally valid inquiry, order or similar legal process;
- To investigate both in the case of a breach of an agreement or contravention of law;
- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, establish, exercise or defend a legal claim, investigate fraud or respond to a government request;
- To any other third party with your prior consent to do so.
If Seva Life Practice, LLC engages in a joint promotion with an affiliate and/or partner, we may share your contact information with our affiliate and/or partner to be used in relation to the promotion.
We may share non-personal information (such as the number of daily visitors to a particular web page or the size of an order placed on a certain date) with third parties such as advertising partners. This information does not directly identify you or any user by name.
Third Party Websites
Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect personal information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
Cookies and Other Tracking Technologies
When you use our site we will store cookies on your computer in order to facilitate and customize your use of our site. Cookies are small text files of information stored by the Internet browser on your computer or device. For example, we may use cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware. Some of our cookies are served by us, and some are served by third parties who are delivering services on our behalf. Seva Life Practice, LLC has no influence on the processing of Personal Information by these providers.
You may set your Internet web browser to refuse cookies or to remove cookies from your hard drive. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block them using different browsers. By blocking or deleting cookies used on our website and mobile application, you may not be able to take full advantage of our services.
The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.
Use of Social Plugins
Seva Life Practice, LLC Website/Applications may use social media plugins (“plugins”) from social networks like Meta, TikTok, Pinterest, Facebook, LinkedIn, Google+ and Twitter (“Social Network”). The Plugins are identified by the respective social media logo or the respective suffix (the “Button”).
If you visit a page on the Seva Life Practice, LLC Website/Application that contains Plugins, your browser will establish a direct connection to the Social Network server and load the Button from there, At the time the Social Network will know that the respective page on the Seva Life Practice, LLC Website/Application has been visited. If you click on a Button, you establish a direct connection to the respective Social Network. By clicking the applicable Button, you accept and consent to the transmission of your data to the Social Network, it can also associate your visit to theSeva Life Practice, LLC Website/Application.
If you do not wish your data to be transmitted to the applicable Social Network via Seva Life Practice, LLC Website/Application, ensure that you are not logged into the Social Network before visiting the Seva Life Practice, LLC Website/Application], and do not click on any Plugins while on the Seva Life Practice, LLC Website/Application.
For information about the scope and purpose of data collection by these social media companies, and your rights and the settings you can configure to protect your privacy, please refer to their privacy policies.
Children Under the Age of 16
This Site is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. Our policy is that we do not knowingly collect, use or disclose personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.
If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at janice@theshiftin.com.
Seva Life Practice, LLC does not knowingly collect or use any Personal Information from online visitors under the age of 16. Seva Life Practice, LLC does not knowingly allow visitors under the age of 16 to participate in any promotions or contests made available on Seva Life Practice, LLC Website/Applications from time to time.
Email Policies
We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Information Sharing.
We will maintain the information you send via e-mail in accordance with applicable federal law.
In compliance with the CAN-SPAM Act, all e-mails sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.
Our emails provide users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at any time or using the contact form on the website.
Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.
Notification of Privacy Statement Changes
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this policy for the latest information on our privacy practices.
Non-United States Visitors
If you are a non-U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States where laws regarding processing of personal information may be less stringent than the laws in your country and where your personal information may be accessed by the courts, law enforcement and national security authorities as required under the laws of those jurisdictions. By providing your data, you consent to such transfer.
GDPR
If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Those rights include:
- We will retain the any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) the Company decides that the value in retaining the data is outweighed by the costs of retaining it.
- You have the right to request access to your data that the Company stores and the rights to either rectify or erase your personal data.
- You have the right to seek restrictions on the processing of your data.
- You have the right to object to the processing of your data and the right to the portability of your data.
- To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
- You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.
- We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
For further information on each of these rights (including the circumstances in which they may apply), see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
CCPA
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting or selling personal information;
- The categories of third parties with whom we share personal information, if any; and
- The specific pieces of personal information we have collected about you.
Please note that we are not required to:
- Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
- Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
- The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
- The categories of personal information that we disclosed about you for a business purpose.
- You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: https://practice.theshiftin.com/cookiepolicy.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
- *Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Exercising your Privacy Rights & Contact Information
If you would like to exercise any of your rights as described in this Privacy Policy, please: Email us at: janice@theshiftin.com
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
California “Shine the Light” Privacy Rights
California’s “Shine the Light” law permits those Seva Life Practice, LLC customers who are residents of California to annually request a list of their Personal Information (if any) that Seva Life Practice, LLC disclosed to third parties for direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. At this time, Seva Life Practice, LLCcurrently does not share any Personal Information with third parties for direct marketing purposes.
If you have any questions about privacy practices, please contact the us using the support/contact us form on the Website. You can use the contact link on your online site or email support@zenler.com to get the contact information of the Website instructors and administrator(s).
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 reach us via the contact us form on the Website.
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 60 days. Occasionally it may take us longer than 60 days 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.
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. For more information about the cookies we use, please see Cookie Policy.
Age Limitations
By providing us with your data, you warrant to us that you are over 13 years of age.
How to contact us
You can contact Seva Life Practice, LLC at any time if you have any questions about this Privacy Policy or our practices, or if you are seeking to exercise any of your statutory rights.
You may contact us via the support/contact us form on the Website.
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 via the support/contact us form OR update your profile in your account.