Effective November 11, 2019
If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 3.
1. The Basics
A. About Us
LBI Financial is an online marketing platform (the "Services") operated by Paul Horrocks ("we," "us," "our," and "LBI Financial").
B. Key Terms
"Personal Information" means any information that identifies or can be used to identify a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, phone number, date of birth, email address, postal address, gender, occupation, life events or other demographic information.
"Visitor" means any person who visits any of our Websites.
"you" and "your" means a Visitor.
2. Privacy for Visitors
This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section "you" and "your" refers to Visitors.
A. Information We Collect
(i) Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information) in order to request a quote, apply for a role, or otherwise submit inquiries to us. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.
The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.
(ii) Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.
B. Use of Personal Information
We may use the information we collect through our Websites for a range of reasons, including:
- To provide, operate, optimize, and maintain our Websites.
- To send you information for marketing purposes, in accordance with your marketing preferences.
- For recruitment purposes if you have applied for a role.
- To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
- To manage our Websites and system administration and security.
- To improve the navigation and content of our Websites.
- To identify any server problems or other IT or network issues.
- To process transactions and to set up online accounts.
- To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
- To carry out research and development to improve our products and services.
- To customize content and layout of the Websites.
- To carry out other legitimate business purposes, as well as other lawful purposes.
- To comply with any compliance rules or investigations required by the company and agency with whom we associate.
- To provide aggregate reporting on your activity and use of the Services to the company and agency with whom we associate.
C. Public Information and Third-Party Websites
- Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us at firstname.lastname@example.org If we are unable to remove your information, we will tell you why.
- Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms, including Facebook, Twitter, Instagram and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
D. Cookies and Tracking Technologies
E. Other Data Protection Rights
You have the following data protection rights:
- To access, correct, update, or request deletion of your Personal Information. MyNameFlow takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by emailing us at email@example.com. We will consider your request in accordance with applicable laws.
- In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at firstname.lastname@example.org.
- Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
3. General Information
A. How We Share Information
(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(v) Any other person with your consent.
(vi) To comply with any compliance rules or investigations required by the company and agency with we associate.
(vii) To provide aggregate reporting on your activity and use of the Services to the company and agency with whom we associate.
B. Legal Basis for Processing Personal Information (EEA Persons Only)
If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.
C. Your Choices and Opt-Outs
Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, annual reviews and billing information) are considered transactional and necessary if you are a client.
D. Our Security
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at email@example.com.
E. International Transfers
(i) We operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Members a Data Processing Agreement.
F. Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our Services or market to you.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
G. California Privacy
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us at firstname.lastname@example.org.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receives a “Do Not Track” signal from a Visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.
H. Changes to this Policy
I. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please email us at email@example.com. You may also contact us by postal mail or email at:
For EEA Residents:
For the purposes of EU data protection legislation, Paul Horrocks is the controller of your Personal Information. Our Data Protection Officer can be contacted at firstname.lastname@example.org.
For Non-EEA Residents:
Attn. Privacy Officer
77 West 55th St. Suite 9J
New York, NY 10019
4. Acknowledgment of Consent
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner or service provider (in this case, Paul Horrocks) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website or service you are using (such as advertising, interactive content and analytics). The third parties that set these third party cookies can recognize your computer both when it visits the website or service in question and also when it visits certain other websites or services.
Cookies served through our Websites
The specific types of first and third party cookies served through our Websites and the purposes they perform are described in further detail below:
Essential Website Cookies
These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the websites, you cannot refuse them without impacting how our websites function.
- 1P_JAR CONSENT
Analytics and Customization Cookies
These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the websites, you cannot refuse them without impacting how our websites function
Advertising (Targeting) Cookies
These cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. For further information, see the section of the Cookie Statement entitled "Targeted online advertising".
- CONSENT NID
Other tracking technologies
We and our third party partners may use other, similar technologies from time to time, like web beacons, pixels (or “clear gifs”) and other tracking technologies. These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or, in the case of web beacons, opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to serve targeted advertisements to you and others like you, to improve site performance, and to measure the success of marketing campaigns. While you may not have the ability to specifically reject or disable these tracking technologies, in many instances, these technologies are reliant on cookies to function properly; accordingly, in those instances, declining cookies will impair functioning of these technologies.
Targeted online advertising
We have engaged one or more third party service providers to track and analyze both individualized usage and volume statistical information from interactions with our Websites. We also partner with one or more third parties (such as advertisers and ad networks) to display advertising on our Websites and/or to manage and serve advertising on other sites.
Cookies served through the Services
We automatically place single pixel gifs, also known as web beacons, in every email sent by us. These are tiny graphic files that contain unique identifiers that enable us to recognize when you have opened an email or clicked certain links. These technologies record your email address, IP address, date, and time associated with each open and click for a campaign. We use this data to create reports about how an email campaign performed and what actions users took.
Google remarketing ads: Our Google remarketing ads feature (also known as web retargeting ads) allows us to create and manage advertisements on the Google Display Network. When we elects to use this feature, we install a Google tracking pixel on our site. These technologies facilitate the placement of advertising campaigns on the Google Display Network and enable us to receive reporting about the performance of these advertising campaigns. To refuse these cookies, please click on the relevant opt-out link here: https://www.google.com/settings/ads/pluginFacebook ads: Our Facebook ads feature allows us to display ads within the Facebook platform. We installs a Facebook tracking pixel on our website. These tracking technologies facilitate the placement of advertising campaigns on the Facebook platform and enable us to receive reporting about the performance of these advertising campaigns. Facebook does not provide an opt-out link for its cookies. For more information about Facebook cookies, please click here: https://www.facebook.com/policies/cookies/.
Product retargeting emails: Our product retargeting emails feature allows us to promote products and services. When you click a link within a product retargeting email, we drop a cookie on your device. This cookie allows MyNameFlow to track attribution rates and browser activity and receive reporting regarding the success of our product retargeting emails.
Popup forms: We deploy a cookie that recognizes whether a visitor to our Site has previously viewed a popup form and ensures the same visitor does not see the form again for a period of up to one year.
How often will you update this Cookie Statement?
Where can I get further information?