1. Introduction
This privacy notice provides you with details of how we collect and process your personal data through your use of our site at http://aligntopurpose.com

By providing us with your data, you warrant to us that you are over 13 years of age.

Align to Purpose / Shani Abergel is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details
Our full details are:

Full name of legal entity:
Shani Abergel

Email address:
admin@tuningpoints.com

Postal address:
287 S. Main Street
Suite 12
Lambertville, NJ 18530

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 info@aligntopurpose.com

2. What Data Do We Collect About You, For What Purpose and On What Grounds We Process It
Personal data means any information capable of identifying an individual. It does not include anonymized data. We may process the following categories of personal data about you:

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. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests that in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal
claims.
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. 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 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. 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 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. We process this data to analyze 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 that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize drawings and free give-aways, 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.
Sensitive Data We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook ads 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).

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious 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.

Where we are required to collect personal data by law, or under the terms of the contract between us and
you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to
cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if
necessary. For more information on this please email us at questions@heroicpublicspeaking.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.We do not carry out automated decision making or any type of automated profiling.

3. How We Collect Your Personal Data
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 cookiepolicy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

‍4. 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, we may send you marketing communications
from us if (i) you made a purchase or asked for information from us
about our goods or services or (ii) 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, coming to this Privacy Policy, and
checking or unchecking relevant boxes to adjust your marketing
preferences OR by emailing us at questions@heroicpublicspeaking.com.

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.

‍5. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below:

Other companies in our group who provide services to us.
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers
Government bodies that require us to report processing activities.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
‍

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 within our group of companies that 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 in place:

We will only transfer your personal data to countries that the European
Commission have approved as providing an adequate level of protection
for personal data by; 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
If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to
them, as they have equivalent safeguards in place.
‍

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.

7. Data Security
We have put in place security measures to prevent your personal data from
being accidentally lost, used, altered, disclosed, or accessed without
authorization. We also allow access to your personal data only to those
employees and partners who have a business need to know such data. They
will only process your personal data on our instructions and they must
keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach if we are legally required to.

‍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.

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.

‍9. Your Legal Rights
Under data protection laws you have rights in relation to your personal data
that include the right to request access, correction, erasure,
restriction, transfer, to object to processing, to portability of data
and (where the lawful ground of processing is consent) to withdraw
consent.

If you wish to exercise any of the rights set out above, please email us at questions@heroicpublicspeaking.com.

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 or 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 a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data,
you have the right to complain to the relevant EU supervisory authority
for data protection issues. 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.

‍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.

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