1. INTRODUCTION

All Girls Allowed (“we” or “us”), producers of the Joyful Life Programs platform, is committed to maintaining strong and meaningful protections for our users. We provide service and information to individuals via joyfullifeprograms.org (the “Website” and the “Services”). This Privacy Policy (the “Policy”) describes the types of personal information we may collect or receive in connection with these Services and our practices for collecting, using, maintaining, protecting, and disclosing that personal information. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.

We process your personal information only when we have an appropriate basis. For example, we may process your personal information as necessary to provide Services that are subject to terms you have accepted, such as our website’s terms of service, when necessary to comply with legal obligations, pursuant to your consent, or for purposes of pursuing our legitimate interests (such as providing and improving our Services, fixing bugs, performing analysis and analytics, communicating with you, preventing fraud, enforcing legal claims, and security purposes) if doing so is consistent with your rights and appropriate to the context.

2. INFORMATION WE COLLECT ABOUT YOU

When you create an account on the Website, we may collect contact information, such as name and e-mail address. When you use or access certain Website Services such as your account profile or our survey, we may collect additional personal information as follows:

• Your phone number, mailing address, state and country of residence, date of birth.
• How you heard about the Website.
• Your learning preferences, areas of interest, and personal growth goals.
• Information you submit when you register for or log into our Service, such as authentication credentials.
• Educational information.
• Registration information associated with participation in events, webinars, and online courses.

We may collect information at live events, such as when we collect your contact information at an event, retreat, seminar, or class. We may also collect comments or other information we receive when you interact with our social media accounts, such as Twitter, Vimeo, and Facebook.

When you use the Services, we may automatically collect information, such as the following:

• Your device type, manufacturer, operating system name, and operating system version.
• Name, version, and other information about the online services and software you are using in connection with the Services (such as mobile apps).
• Your mobile device identifier (such as Android UDID and iOS UUID).
• The Internet protocol (IP) address your device uses to access the Internet.
• Your geo-location.
• Other information, such as usage analytics data.

We may use the following automated technology to collect information in connection with the Services:

• Browser and Device Information: Certain information is collected by most browsers or automatically through your device, such as your device type, operating system name and version, device manufacturer and model, Internet browser type and version and the name and version of the online services (such as apps) you are using. We use this information to ensure that the Services function properly.

• Cookies: Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL, and other website traffic data. We may use cookies for purposes including enabling you to log in, and stay logged in, to the Services. Refer to the Choices section of this policy for information on how you may be able to reject or disable cookies.

• Google Analytics: Google Analytics uses cookies to help us analyze how visitors use the Services. The information generated by the cookies about your use of the Services includes your IP address, and will be transmitted to and stored by Google on its servers.

  Google will use this information for the purpose of evaluating your use of our websites, creating reports on website activity, and providing other services relating to Internet usage.

  Google may also pass this information onto third parties when required to do so by judicial or administrative process or otherwise to the extent required by law, or when such third parties process the information on Google’s behalf. If you so choose, you may be able to opt out by turning off cookies in the preferences settings in your browser, or by downloading and installing the Google Analytics Opt-Out Browser Add-On from http://tools.google.com/dlpage/gaoptout

  For more information on Google Analytics, including how Google Analytics collects, uses, and discloses information, refer to the following page: https://policies.google.com/technologies/partner-sites

• IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Website Services, along with the time of the visit and the page(s) that were visited.

  Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering our Services. We may also derive your approximate location from your IP address to understand from what regions of the world our website visitors come.

3. HOW WE USE YOUR INFORMATION

We may use personal information that we collect or receive about you for purposes including the following:

• Providing you with the Services and responding to your requests.
• Completing transactions and performing our contractual obligations.
• Communicating with you and providing you with information that you request from us or which we feel may interest you, including newsletters, survey reports, invitations to events, etc.
• To create aggregate or deidentified data.
• Understanding how our users use our Services.
• Improving our Services.
• Calculating user levels and diagnosing server problems.
• To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our Services.
• Determining your approximate location.
• Customizing our Services according to your individual interests and preferences.
• Analyze and enhancing our marketing communications and strategies.
• Storing information about your preferences and recognizing you when you use the Services.
• Notifying you when updates to the Services are available and of changes to the Services.
• Evaluating and improving the effectiveness of our operations, including our Services, developing new services, and performing other internal business operations, including as described elsewhere in this Policy.
• Enforcing our policies, terms of service, or rights.
• Protecting the rights, property, or safety of us, our affiliates, our employees, our users, and others.
• Complying with any court order, law, or legal process, and responding to lawful requests from public authorities, including to meet national security or law enforcement requirements.
• Investigating or preventing unlawful activities or misuse of the Services, and/or complying with any court order, law, or legal process, including to respond to any government or regulatory request.
• For such purposes as you may authorize or direct.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated, anonymized information about our users to third parties, including our content partners, without restriction. We may disclose information (personal or otherwise) collected about you:

• To our content partners based on your expressed interest.
• To our affiliates.
• To our contractors, service providers, and other third parties we use to support our business.
• To comply with any court order, law, or legal process, and respond to lawful requests from public authorities, including to meet national security or law enforcement requirements.
• To enforce our policies, terms of service, or rights arising from any contracts entered into between you and us.
• To investigate or prevent unlawful activities or misuse of the Services.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others.
• To a buyer or other successor or organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
• With such other parties, or for such other purposes, as you may authorize or direct.

5. DELETING YOUR DATA

You can remove your data from the Joyful Life Programs database and platform at any time. When logged in, go to My Account | My Profile. Scroll to the bottom of the profile form and click the Delete Account button. The screen will prompt you to confirm your intent to delete your account from the platform. This will remove all personal data collected from you along with your email and password. Resource reviews you wrote will remain under a generic username.

6. CONTROLLING ACCESS

We strive to provide you with choices regarding your personal information. We have created the following mechanisms to provide you with control over your information:

• Cookies. If you do not want information collected through the use of cookies, you may be able to adjust your browser or device settings to automatically decline cookies or be given the choice of declining or accepting the transfer to your device of a particular cookie (or cookies) from a particular site. If, however, you do not accept cookies, you may experience some reduced functionality associated with the Services.
• Email. Use the Account Profile notifications tab to opt out of receiving emails from us for messages that are not the direct response to your inquiry.

You may use the Account Profile area to modify the data we have about you or to remove your account from our system.

Some Internet browsers have a “do-not-track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our Services are not set up to respond to do-not-track signals. We may permit third parties to use the Services to collect personal information about users’ online activities over time and across different websites.

7. DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include storing personal information you provide to us on secure cloud servers.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas, such as message boards.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information collected, received, or transmitted in connection with our Services. We are not responsible for circumvention of any privacy settings or security measures we provide.

8. DATA RETENTION

We store personal information for as long as we reasonably need it to fulfill the purposes for which it was collected. We will also retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. INTERNATIONAL DATA TRANSFERS

We may transfer your personal information to the United States and other countries that may not have the same data protection laws as the country in which you reside. Some of these jurisdictions may not have been deemed adequate by the European Commission or other relevant authorities to provide a comparable level of protection to that of the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”). When we transfer personal information subject to the data protection laws of the EEA, Switzerland, or the UK, we will rely on a legal framework that provides appropriate safeguards, which include the standard contractual clauses, binding corporate rules, or another appropriate framework.

10. INQUIRIES AND COMPLAINTS PROCESS FOR EEA, SWISS, AND UK INDIVIDUALS

If you are located in the EEA, Switzerland, or the UK: you may have additional rights to request access to, correction of, erasure of, or the transfer of your personal information, as well as the right to object to or restrict the processing of your personal information. You may exercise these rights, if applicable, by contacting us as described in the Contact Information section of this Policy. You may also have the right to lodge a complaint with an EEA, Swiss, or UK supervisory authority, as applicable.

11. ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA AND YOUR CALIFORNIA PRIVACY RIGHTS

This section of the Policy applies only to residents of the State of California (for the purposes of this section 10 of the Policy, “consumers” or “you”), and generally describes how we collect, use, and disclose the personal information of consumers or consumer households (“California Personal Information”). However, California Personal Information does not include, and this section of the Policy does not apply to:

• Personal information excluded from the California Consumer Privacy Act (“CCPA”).
• Personal information, emergency contact information, and benefits administration information we collect about a consumer in the course of that consumer acting as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor to the extent we use that information within the context of that consumer’s role as our job applicant, employee, owner, director, officer, medical staff member, or contractor.
• Personal information reflecting a communication or a transaction between us and a consumer’s organization that relates to obtaining products and services from us.

This section of the Policy applies only to the extent we direct the purposes and means of processing California Personal Information and otherwise qualify as a “non-profit organization” under the CCPA. It does not apply to information we collect, disclose, or otherwise process as a “service provider” under the CCPA on behalf of our users and content partners.

A. California Personal Information We Collect

We may have collected the following categories of California Personal Information in the preceding 12 months:

• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, physical characteristics or description, address, telephone number, education, credit card number, debit card number, or any other financial information.
• Identifiers, including unique and online identifiers.
• Internet and electronic activity information.
• Geolocation data.
• Inferences drawn from your personal information.

B. Sources of California Personal Information We Collect

We collect California Personal Information from the sources described in the Information We Collect About You section of this Policy.

C. Purposes for Which We Use, Disclose, and Sell California Personal Information

We may use, disclose, and sell the categories of California Personal Information described in the California Personal Information We Collect section above for one or more of the business and commercial purposes described in the How We Use Your Information section above. We may disclose this information to the categories of third parties identified in the Disclosure of Your Information section above for the business and commercial purposes described in the How We Use Your Information section above.

D. Disclosures of California Personal Information for a Business Purpose in the Preceding 12 Months

In the preceding 12 months, we may have disclosed the categories of California Personal Information described in the California Personal Information We Collect section above to the categories of third parties identified in the Disclosure of Your Information section above for a business purpose.

E. Sales of California Personal Information

We do not sell California Personal Information.

F. California Personal Information Rights and Choices

The CCPA and other California laws provide consumers with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise those rights.

• Opting Out of Sales of California Personal Information. You have the right to direct us to not sell your California Personal Information.

  To exercise the right to opt-out, you or your authorized agent may submit a request to us by visiting the following page: Do Not Sell My Personal Information, or by calling the following toll-free number: +1 (833) 470-1234.

We may deny an opt-out request submitted by your authorized agent if the authorized agent does not submit written proof of authorization to act on your behalf.

• Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the Exercising Access, Data Portability, and Deletion Rights section below, we will disclose to you, depending on the scope of the request:

  • The categories of California Personal Information we collected about you.
  • The categories of sources for the California Personal Information we collected about you.
  • Our business or commercial purpose for collecting California Personal Information about you.
  • The categories of third parties with which we share your California Personal Information.
  • The specific pieces of California Personal Information we collected about you.
  • If we disclosed or sold your California Personal Information for a business purpose, a list of the categories of third parties to whom we disclosed California Personal Information for a business purpose identifying the categories of California Personal Information disclosed to those parties in the preceding 12 months and a list identifying the California Personal Information categories sold and the categories of third parties who purchased that California Personal Information.
  • Deletion Request Rights. You have the right to request that we delete your California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the Exercising Access, Data Portability, and Deletion Rights section below, we will delete your California Personal Information from our records, unless an exception applies.

  • Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

    Emailing us at joyfullifeprograms@allgirlsallowed.org
    Calling the All Girls Allowed office at 617-492-9099.

Only you, or an agent that you provide written permission to act on your behalf, may make a verifiable consumer request related to your California Personal Information. If an authorized agent makes a request on your behalf, prior to responding we may require the authorized agent to present written and signed proof of authorization to act on your behalf, verify your identity, and confirm the authorized agent’s permission to act on your behalf directly. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent of that person. In order to verify your request, we may require you to provide information such as your first and last name, email address, zip code, and any other information necessary for us to verify your request. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.

Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.

• Non-Discrimination. Subject to certain exceptions, you have the rights to not receive discriminatory treatment for exercising your access, data portability, opt-out, and deletion rights described above.

• Direct Marketing Disclosures. Consumers who have an established business relationship with us for personal, family, or household purposes may request certain information regarding our disclosure of certain personal information to third parties for those parties’ own direct marketing purposes. If you are a consumer who has such an established business relationship with us and wish to make such a request please send us your written request by mail to:

  All Girls Allowed

  101 Huntington Ave., Suite 2200
  Boston, MA 02199

  Attention: Chief Compliance Officer.

• Right to Request Removal for Consumers Under the Age of 18. Consumers under the age of 18 who are registered users of the Website Services may request and obtain removal of content or information they post on the Website Services. Such request for removal does not ensure complete or comprehensive removal of the content or information posted on the Website Services. To receive instructions on how to request and obtain removal of content or information posted on the Website Services, please contact us as described below in the Contact Information section.

12. CHANGES TO OUR POLICY

It is our practice to post any changes we make to our Policy on this page. The date this Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this Policy to check for any changes.

13. CHILDREN

Our Services are not intended for children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If you are a resident of California, under the age of 18, and a registered user of the Website Services, you may refer to the Your California Privacy Rights section above for additional information.

14. EXTERNAL WEBSITES AND SERVICES

Some hyperlinks and banners contained in our Services link to third-party websites or services. We do not operate these third-party websites or services and they are not subject to this Policy. For information on how your Personal Information will be collected, used, and disclosed, check the privacy policies of these third-party websites or services.

15. CONTENT YOU SUBMIT/POST

User Content such as ratings and reviews that you post on the Site will be treated as non–confidential and non–proprietary to you and may be viewed by you and/or other users of this Site. We cannot guarantee that other users will not copy, modify, distribute or otherwise use the User Content that you share. Therefore, if you have an idea or information that you would like to keep confidential, and/or do not want others to use, do not post it on the Site. We are not responsible for any user’s misuse or misappropriation of any User Content you post on the Site.

16. CONTACT INFORMATION

To ask questions or comment about this Policy and our privacy practices, contact us at joyfullifeprograms@allgirlsallowed.org or via mail at: