Online Privacy Policy

Your privacy is important to us, and so is being transparent about how we collect, use, store, transfer and share information about you. The portion of this Privacy Policy that relates to the European Union’s General Data Privacy Regulation may apply to some of the data that you provide to us offline and/or through other means, as well (for example, at a live event, via telephone, or through the mail).

“Coscia Enterprises”, “Silva Method of Boston-Chicago-Connecticut”, “Ken Coscia Training” (the “Company”) respects the privacy concerns of the users of its website, https://www.Trustyourintuitionacademy.com, https://silvamethodct.com, 
https://www.Kencoscia.com  and the services provided therein (the “Site”). The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information may be used.

Please also review the Terms of Use at https://www.Trustyourintuitionacademy.com/pages/terms which also govern use of this Site.

The following Privacy Policy governs the online information collection practices of Ken Coscia, the Silva Method of Boston, Connecticut and Chicago, the Trust Your Intuition Academy and its associated global entities (“Company,” “we” or “us”). Specifically, it outlines the types of information that we gather about you while you are using www.Trustyourintuitionacademy.com, www.silvamethodct.com and other websites operated by Company (collectively, the “Site”), and the ways in which we use this information. This Privacy Policy, including our children’s privacy statement, applies primarily to information which we collect online.

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our Company collects information from all end users of our Internet services (the “Services”), including those who access some of our Services. 

What This Policy Covers

This Policy applies to personal information that we obtain about our customers and the other individuals with whom we do business and to the use of that personal information in any form – whether oral, electronic or written, all in accordance with applicable global data privacy laws.The term “personal information” in this Policy refers to information that does identify or is capable of identifying you as an individual. This Policy applies to all the products, services, websites and apps offered by the “Company” (“Services”).

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy. In an effort to comply with changes in technology, and the adoption of new regulations and laws, we may need to change our Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on this website and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Site after we post any such changes, you accept the Privacy Policy as modified.

How This Policy Applies

This Policy describes the information we collect from you, how we use that information and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. 

If you do not agree with this Policy, do not access or use our services or interact with any other aspect of our business. 

As one of our customers with whom we do business, you understand and agree that we collect, store, use, transfer and disclose your personal information in accordance with this Policy.

How We Collect Your Personal Information

Your personal information may be collected by us in a number of ways, including:

• when you provide us with information in relation to your attendance at any of our course introductions, courses, seminars or other hosted events and services.
• when you provide information to us by filling in forms on any of our websites.
• when you complete surveys that we use for research purposes; and
• when you contact us, for example, to inquire about our services.

Types of Personal Information We Collect

In order for you to use our Services, we collect and process certain information, including personal information.

Depending on your use of the Services, the types of personal information that we collect and process (which may vary by jurisdiction based on applicable law) include:

Sensitive Personal Information. There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries. Those laws generally define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s, racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, philosophical beliefs, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, sexual life, sexual orientation, biometric data or judicial data (including information concerning the commission or alleged commission of a criminal offence). In some very rare instances, financial records may form part of Sensitive Personal Information where you are located. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law and will obtain your explicit consent to do so. 

How We Use Your Personal Information

We use the information we collect from you to provide you the extraordinary level of service you request and expect from the Ken Coscia brand. Our primary goal in collecting your information, including your personal information, is to provide you with a smooth, efficient, and customized experience. As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather and never selling your data.

We may use your information as set forth below:

Service Administration. We use your personal information to create and administer your account, keep your account secure, contact you, complete a purchase or provide the services you have requested, customize your experience, to carry out services we have agreed to provide you and to protect our Services (including to verify the identities of creators and prevent fraud and abuse), to improve the content and methods of delivery of our website and provide, manage and improve our services.

Communication. We use your information to send communications about the Services, including confirming your purchases, sending invoices, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We will contact you through email, phone calls, notices posted on our websites, and other ways, including text messages. 

Payment Information. We collect certain payment and billing information when you register for certain paid Services. For example, you might provide payment information, such as payment card details, which we collect via secure payment processing services. We do not store payment details nor do we share your payment information with third parties for any purpose other than the provision of the requested Service.

Marketing. Information you submit, such as your name, email, other contact information, may be collected by the “Company” (Coscia Enterprises, Ken Coscia)  for internal marketing and development purposes as well as to respond to your inquiries. With your permission we may use your personal information to provide or offer you promotions and featured specials, as well as other marketing messages in accordance with any communication preferences you have expressed, to send you marketing messages; and to conduct surveys. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), and other means.

Meeting and Event Planning. We may use your personal information to provide you with a better or more personalized level of service, including responding to your requests for information and services from a third party (such as travel, accommodation or transportation arrangements).

Personal Access. To allow you to use or access secure areas of our website, when you choose to do so and when our terms of use permit.

Other. In addition, the “Company” (Coscia Enterprises, Ken Coscia) may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of the “Company” (Coscia Enterprises, Ken Coscia) , site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites’ terms and conditions, and (vii) respond to an emergency.

You may always opt-out of receiving future mailings as provided below. The Company does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.

The Company may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Site, or anyone else that could be harmed by such activities.

Children Age 18 and Under: The Company recognizes the special obligation to protect personally identifiable information obtained from children age 18 and under. AS SUCH, IF YOU ARE 18 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 18 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.

The Company nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:

1. Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
2. Know the sites your kids are visiting and which sites are appropriate.
3. Look for Website privacy policies. Know how your child’s information is treated.
4. Check out the FTC’s site for more tips on protecting children’s privacy online

Lawful Basis For Processing (for users in the European Economic Area “EEA”) Only:

Lawful basis for processing. If you are an individual in the European Union (EU), we collect and process information about you only where we have a lawful basis for doing so under applicable EU laws, including, but not limited to, The EU General Data Protection Regulation (“GDPR”). The lawful basis depends on the Services you use and how you use them. Our lawful basis include:

Consent. Under certain circumstances, personal information may be processed on the basis that you have consented to such processing. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind and withdraw your consent at any time, but this will not affect any processing that has already taken place.

Contractual Necessity. Personal information may be processed on the basis that such processing is necessary in order to enter into or perform a contract with you. In certain circumstances, we need your personal data to comply with our contractual obligation to deliver the Services we provide to you. 

Compliance With Legal Obligations. Personal information may be processed on the basis that we have a legal obligation to perform such processing. For example, tax laws may require us to retain records of payments you made through our Services.

Legitimate Interests. This is a technical term in data protection law which essentially means we have a good and fair reason to use your personal information and we do so in ways which do not interfere with your interests, freedoms and fundamental rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business. 

Use of Cookies: Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using our Site easier by, among other things, saving your passwords and preferences for you. These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.

Company uses the following cookies on the TrustYourIntuitionAcademy Site:

Cookie	Name	Purpose
_kjb_session	Kajabi session cookie	Tracks your active admin session so you don’t need to re-login
kjba	Kajabi affiliate token	Tracks which affiliate has referred an offer purchase
_abv	Admin bar hidden	Tracks whether the user wishes their admin previewing bar to be hidden

Third Party Data:

Affiliate links

Occasionally you may have clicked on one of Mindvalley’s affiliate links and signed up or bought something via that link. In this case, the person or organization in charge of the affiliate link will have the information that you have submitted. This may be your email address, name, address, or whatever else they asked you. If you have signed up for bought something from Mindvalley via an affiliate link, please check the privacy policy on their site.

Online shopping

If you order services or products directly from our Company we will use the personal information you provide only to process that order. We do not share this information with outside parties except to the extent necessary to complete that order.

If you complete an order for some other company(ies) that may be linked to our Site, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient’s name, address, and phone number. Our company has no control over the third parties’ use of any personal information you provide when placing such an order. Please exercise care when doing so. We recommend that you familiarize yourself with the Privacy and Terms of Use policies of any other company(ies) whose web sites you may access from our site.

Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

Site Analytics

We work with third party service providers who use the technologies described in this section and other tracking means to conduct analytics to help us track and understand how visitors use our Site. For example, we use a variety of third party web analytics, including Google Analytics, to help us improve our Site’s performance and user experiences. We analyze how users interact with our websites so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the online experience we offer all our customers.

Security

The security of your personal information is important to us. We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal information to us online will be encrypted. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the “https” prefix, you should not assume that the personal information that you are being asked to provide will be encrypted prior to transmission.

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.

Social Media

Our websites may also contain plug-ins and other features that integrate third party social media platforms into our websites. You are able to click on such links. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.

Links to External Sites: The Company is not responsible for the content or practices of third party websites that may be linked to the Site. The Company is also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective privacy policy and practices prior to disclosing any information.

Bulletin Boards and Chat Areas: Guests of the Site are solely responsible for the content of messages they post on the Company’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.

Choice/Opt-Out: The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us at [email protected], including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.

Transfer of Information Across National Borders: Our site and various information we collect are operated on servers located in various jurisdictions, including the United States. When you access or use the Site and/or our services, personal information about you may be transferred outside the country in which you are situated to these other locations. The Company’s policies ensure that such personal information is protected to the same standard when processed by any Company entity or office around the world. We also ensure that appropriate contracts containing standard data protection clauses approved by the European Commission to protect that information and the rights of individuals are in place with any and all third-party service providers we may use.

Your Access to and Control Over Your Personally Identifiable Information: At any time, but only once per calendar year, or as otherwise required under applicable law, users may contact Company to review the personally identifiable information that Company has collected about you. If you discover any errors, please notify Company and the information will be corrected. To review the personally identifiable information that company has collected about you, please send an email to [email protected] with the subject line: “Personal Information Review Request.” Users may also request that Company delete a user account(s) or, if you have not established a user account, your email address, and any related data at any time. If you wish to delete your user account(s), please email us at [email protected] with the words “Delete Account” in the subject line. If you do not have a user account and wish to delete your email address or other personally identifiable information that you might have provided through your use of the Site, any Games, and/or any Services, please email us at  [email protected] with the words “Delete My Information” in the subject line.

You may also choose to confirm that the Company does not use your personal information in certain ways and/or to otherwise “opt out” of certain uses of that personal information, including without limitation (i) when your personal may to be disclosed to a third party unrelated to the Company and/or parties directly related to providing your Services and/or (ii) when your personal information may be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. If you wish to limit your personal data in either such way, or have other questions about how the Company may use your personal data, please contact us at [email protected]  with the words “Privacy Shield Request” in the subject line.

Advertiser Disclosures

Google Analytics

We use Google Analytics Advertiser Features to optimize our business. Advertiser features include:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• DoubleClick Platform integrations
• Google Analytics Demographics and Interest Reporting

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Site, and match the right audience with the right advertising message.

You can opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page

Facebook

As advertisers on Facebook and through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.
We abide by Facebook’s Data Use Restrictions.

• • Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
  • We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
  • We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
  • We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.

Data Security and Data Privacy Regulation

Our company’s commitment to data security:

We implement a variety of administrative, managerial, and technical security measures to help protect your personal information. Our Company has various internal control standards which relate specifically to the handling of personal information. These include certain controls to help safeguard the information we collect online. Our employees are trained to understand and comply with these controls and we communicate our Privacy Policy, practices and guidelines to our employees. However, while we strive to protect your personal information, you must also take steps to protect your information. We urge you to take every precaution to protect your personal information while you are on the Internet.

Services and websites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information. If we do discover a security breach affecting your data, every effort will be made to provide a notification within 72 hours of our team learning of the occurrence.

General Data Privacy Regulation (GDPR)

The GDPR takes effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.

If you are a resident of the European Economic Area (EEA), or are accessing this Site from within the EEA, you have certain rights with respect to your data. We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to [email protected].

Rights that you may have, depending on the country in which you live, include:

• • Accessing, correcting, updating, or requesting deletion of your information.
    • If you request that your account be deleted, you will lose access to all of our programs in which you are actively registered.
  • Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
  • Opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we send you. Additionally, you may update your email preferences by changing the settings in your account.
  • Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
  • Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available.

Contact Information for Complaints or Concerns: If you have any complaints or concerns about the Company or about this privacy statement, please contact:

Via email: [email protected]

or

Via regular mail: Coscia Enterprises, 335 Meadow Rd., Farmington, CT 06032

Information provided by you via general e-mail inquiries to the Company such as your e-mail address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.

Security: Security for all personally identifiable information is extremely important to us. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, The Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to the Company, you accept that you do so at your own risk.

Your Acceptance of These Terms: By using the Site, you accept the policies and restrictions set forth in this Online Privacy Policy. If you do not agree to this policy, please do not use the Site. This Online Privacy Policy may be revised from time to time by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Online Privacy Policy to which you are bound.

Last Updated: June 7, 2018