Effective Date: May 24, 2018
how Affluence EDU and our affiliates (collectively, the “Company,” “Affluence EDU,” “we,” and “us”) collect, use, disclose,
transfer, store, retain or otherwise process your information when you (whether you are a person or a business)
register for services, purchase services, or otherwise provide information in exchange for services provided
questions about our practices or any of your rights described below. By continuing to interact with our Services,
INFORMATION WE COLLECT ABOUT YOU
We need to collect and process your personal information to run our business and provide you with the Services. If you don’t
want us to collect or process your personal information in the ways described in this policy, you shouldn’t use
the Services. We are not responsible for the content or the privacy policies or practices of any third-party
service providers, third-party websites, or third-party apps.
Information You Provide
We may collect information you provide when you register, sign up, purchase, communicate with us, answer our surveys, upload
content, or otherwise use the Services.
We collect information about you when you use our Services, including:
Identification Information. Your name; email address; mailing address; phone number; photograph;
birthdate; passport, driver’s license, Social Security Taxpayer Identification, or other government-issued
identification; or other historical, contact, and demographic information when you register for, purchase
from, or otherwise request Services from us.
Financial Information. Information such as bank account, payment card numbers, credit reports, and
other publicly available information.
Tax Information. Withholding allowances and tax filing status.
Other Information You Provide. Information that you voluntarily provide to us, including your survey
responses; participation in contests, promotions, or other prospective seller marketing forms or devices;
suggestions for improvements; referrals; details about your background and experience with us; details about
any external transaction or investment history; or any other actions performed on the Services.
Information We Collect From Your Use of our Services
We collect information about you and the devices you use to access the Services, such as your computer, mobile phone, or
tablet. The information that we collect includes:
Precise Geolocation Information. The location of your device. For more information and to learn
how to disable collection of location information, please
Use Information. Information about how you use our Services, including your access time, “log-in”
and “log-out” information, browser type and language, country and language setting on your device, Internet
Protocol (“IP”) address, the domain name of your Internet service provider, other attributes about your browser,
mobile device and operating system, any specific page you visit on our platform, content you view, features
you use, the date and time of your visit to or use of the Services, your search terms, the website you visited
before you visited or used the Services, data about how you interact with our Services, and other clickstream
Information We Collect From Other Sources
We also collect information about you from third parties, including:
Identity Verification. Information from third-party verification services, mailing list providers, and publicly available
Our Services are general audience services not directed at children under the age of 13. We do not knowingly collect personal
information from any user under 13. If we obtain actual knowledge that any information we collect has been provided
by a child under the age of 13, we will promptly delete that information. If you believe we might have any information
from or about a user under 13, please contact us at
HOW WE USE YOUR INFORMATION
We may use information about you for a number of purposes, including:
Providing, Improving, and Developing our Services
Determining whether the Services are available in your country;
Otherwise providing you with Services you choose to use;
Providing, maintaining, and improving our Services;
Developing new products and services;
Delivering the information and support you request, including technical notices, security alerts, and support and administrative
messages including to resolve disputes, collect fees, and provide assistance for problems with our Services
or your account;
Improving, personalizing, and facilitating your use of our Services;
Measuring, tracking, and analyzing trends and usage in connection with your use or the performance of our Services.
Communicating with You About our Services
Sending you information we think you may find useful or which you have requested from us about our products and services.
We may also contact you with offers for additional services we think you will find valuable if you give us
consent. You do not need to provide consent as a condition to purchase our goods or services. This communication
may include contact by:
Text (SMS/MMS) messages
Automated phone calls or text messages
Conducting surveys and collecting feedback about our Services.
Protecting our Services and Maintaining a Trusted Environment
Investigating, detecting, preventing, or reporting fraud, misrepresentations, security breaches or incidents, other potentially
prohibited or illegal activities, or to otherwise help protect your account;
Protecting our, or our customers’ rights or property, or the security or integrity of our Services;
Terms of Service or other applicable agreements or policies;
Verifying your identity
Complying with any applicable laws or regulations, or in response to lawful requests for information from the government
or through legal process;
Fulfilling any other purpose disclosed to you in connection with our Services;
Contact you to resolve disputes, collect payments, and provide assistance with our Services.
Advertising and Marketing
Marketing of our Services;
Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and
rewards offered by us and select partners;
If we send you marketing emails or SMS/MMS text messages, each email and message will contain instructions permitting you
to “opt out” of receiving future marketing or other communications.
If we call you to offer additional Services, you may request to be added to our internal do-not-call list. This will not
remove you from security, legal, or administrative related communications.
To learn more about your choices regarding interest-based advertising and cross-device tracking, please
For any other purpose disclosed to you in connection with our Services from time to time.
HOW WE SHARE YOUR INFORMATION
We may share information about you as follows:
With Our Affiliates
With our group companies and corporate affiliates, for the purposes outlined above.
With Third Parties
With third parties to provide, maintain, and improve our Services, including service providers who access information about
you to perform services on our behalf, as well as financial institutions, payment networks, payment card
associations, partners providing services on our behalf, and other entities in connection with the Services;
With third parties that run advertising campaigns, contests, special offers, or other events or activities on our behalf
or in connection with our Services.
to opt-out, go to:
Safety and Compliance with Law
If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or
governmental request (e.g., tax authorities, law enforcement agencies, etc.); (ii) to enforce or comply with
or property, or the security or integrity of our Services; or (iv) to protect us, users of our Services or
the public from harm, fraud, or potentially prohibited or illegal activities.
With Your Consent
With your consent. For example:
At your direction or as described at the time you agree to share;
When you authorize a third-party application or website to access your information.
Without Your Consent
We also may share (within our group of companies or with third parties) aggregated and anonymized information that does not
specifically identify you or any individual user of our Services.
HOW LONG WE RETAIN YOUR INFORMATION
We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable
law. However, even after you cancel or deactivate your account, we can retain copies of information about you
and any transactions or Services in which you may have participated for a period of time that is consistent with
applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable
law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to
resolve disputes, to address problems with our Services, to assist with investigations, to enforce our
COOKIES AND OTHER SIMILAR TECHNOLOGIES
We use various technologies to collect information when you access or use our Services, including placing a piece of code,
commonly referred to as a “cookie,” or similar technology on your device and using web beacons. Cookies are small
data files that are stored on your hard drive or in your device memory when you visit a website or view a message.
Among other things, cookies support the integrity of our registration process, retain your preferences and account
settings, and help evaluate and compile aggregated statistics about user activity. We will begin collecting information
about you or from activity on devices you use as soon as you use our Services. By using our Services, you permit
us to collect and use your information from activity on devices you use in accordance with this Privacy Notice.
For more information and to learn how to block or delete cookies used in the Services, please
Certain cookies we use last only for the duration of your web or application session and expire when you close your browser
or exit the application. Other cookies are used to remember you when you return to use the Services and, as such,
will last longer.
Remember that you have visited us or used the Services before. This allows us to identify the number of unique visitors we
receive, so that we can provide enough capacity to accommodate all of our users.
Customize elements of the promotional layout and/or content of our Services.
Collect data about the way you interact with our Services.
Collect data to assess and improve our advertising campaigns, including sending information to our business partners.
Allow our business partners (including third parties) to use these tracking technologies to track your behavior on our behalf
on our website(s) or application(s) (including when you use multiple devices) and on partner websites.
Enable third parties to collect data about the way you interact across sites outside of our Services.
Collect anonymous statistical information about how you use the Services (including the length of your web or application
session) and the location from which you access the Services, so that we can improve the Services and learn
which elements and functions of the Services are most popular with our users.
Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.
Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser
settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set.
You also can learn more about cookies by visiting
http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block
cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting
cookies used in the Services, you may not be able to take full advantage of the Services.
We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or
emails. We use web beacons to deliver cookies, track the number of visits to our website and apps, understand
usage and campaign effectiveness, and determine whether an email has been opened and acted upon.
THIRD-PARTY ADVERTISING AND ANALYTICS
We can use third-party service providers to provide site metrics and other analytics services. These third parties can use
cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated
with your device, other applications on your device, the browsers you use to access our Services, webpages viewed,
time spent on webpages, links clicked, and conversion information (e.g., transactions entered into). This information
can be used by Square and third-party service providers on behalf of Square to analyze and track usage of our
Services, determine the popularity of certain content, and better understand how you use our Services. The third-party
service providers that we engage are bound by confidentiality obligations and other restrictions with respect
to their use and collection of your information.
This Privacy Notice does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking
technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you
to check the privacy policies of these third parties to learn about their privacy practices. For more information
about targeted advertising specifically, please visit
Examples of our third-party service providers to help deliver our Services or to connect to our Services include:
You may view, change, or correct information that you have provided by making a request to us using the
contact details below, in which case we may need to verify your identity before viewing or otherwise changing
or correcting your information.
Canceling or Deactivating Your Account
If you wish to cancel or deactivate your account, you can do so by emailing us using the
contact details below.
In order to provide certain Services, we may require access to location information, including precise geolocation information
collected from your device. If you do not consent to collection of this information, certain Services will not
function properly, and you will not be able to use those Services. You can stop our collection of location information
at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications
will no longer function.
Do Not Track
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across
websites. We do not have a mechanism in place to respond to DNT signals. We do track some activity across websites
(including your search terms, the website you visited before you visited or used the Services, and other clickstream
that have enabled DNT signals or similar mechanisms.
You can opt out of receiving promotional messages from us by following the instructions in those messages, by informing the
caller that you would not like to receive future promotional calls or by replying STOP to any SMS/MMS message.
Opting out of receiving communications may impact your use of the Services. If you decide to opt out, we can
still send you non-promotional communications, such as digital receipts and messages about your account or our
ongoing business relations.
California Privacy Rights
California law permits residents of California to request certain details about our disclosure of your personal information
to third parties for direct marketing purposes during the immediately preceding calendar year. If you are a California
resident and would like to request this information, please contact us at the
address listed below.
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from
loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet
is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of
your information. We hold information about you both at our own premises and with the assistance of third-party
STORAGE AND PROCESSING
We may, and we may use third-party service providers to, process and store your information in the United States, Canada,
the European Union, and other countries.
The revised version will be effective on the “Effective Date” listed. We will provide you with prior notice of
material changes in how we use your information, including by email, if you have provided an email address. If
you disagree with these changes, you may cancel at any time. Your continued use of our Services constitutes your
c/o Privacy Matters
380 S. Technology Ct., Ste. 100
Lindon, UT 84043, U.S.A
If you have any questions or concerns regarding our notice, or if you believe our notice or applicable laws relating to the
protection of your personal information have not been respected, you may file a complaint with our Privacy Department
listed above, and we will respond to let you know who will be handling your matter and when you can expect a
further response. We may request additional details from you regarding your concerns and may need to engage or
consult with other parties in order to investigate and address your issue. We may keep records of your request
and any resolution.
Residents of the European Economic Area
If you elect not to provide person data
You may choose not to provide us with your information. However, if you choose not to provide your information, you may not
be able to enjoy the full range of Services.
How to exercise your rights
We take steps to keep your information accurate and up to date. If you reside in the European Economic Area, you have certain
rights to the information that we have collected about you. To exercise your rights to your information,
please email or mail to us using the
contact details above. Subject to applicable law, we will respond to reasonable requests as soon
as practicable, within the limits prescribed by law.
You have the following rights:
Right of access to your Information: You have the right to ask us for confirmation on whether we are processing your information,
and access to the information related on that processing.
Right to correction: You have the right to have your information corrected, as permitted by law.
Right to erasure: You have the right to ask us to delete your information, as permitted by law. This right may be exercised
among other things: (i) when your information is no longer necessary for the purposes for which it
was collected or otherwise processed; (ii) when you withdraw consent on which processing is based;
(iii) when you object to processing; or, (iv) when your information has been unlawfully processed.
Right to restriction of processing: You have the right to request the limiting of our processing under limited circumstances,
including: when the accuracy of your information is contested; when the processing is unlawful, and
you oppose the erasure of your information and request the restriction of the use of your information
instead; or when you have objected to processing.
Right to data portability: You have the right to receive the information that you have provided to us, in a structured, commonly
used and machine-readable format, and you have the right to transmit that information to another
controller, including to have it transmitted directly, where technically feasible.
Right to object: You have the right to object to our processing of your information, as permitted by law. This right is limited
to processing. After which, we will no longer process your information unless we can demonstrate
compelling legitimate grounds for the processing that override your interests, rights and freedoms
or for the establishment, exercise or defense of legal claims.
How we may disclose your information
The GDPR and national laws of European Union member states implementing the Regulation permit the sharing of information
relating to users who are residents of the European Economic Area with third parties only under certain
circumstances. If you reside in the European Economic Area, we will only share your information as described
How We Share Your Information if we are permitted to do so under applicable European and national
data protection laws and regulations.
Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials
or information. When required by local law, when marketing consent is obtained, we use the double-opt-in
method (confirmation of your email address by email before sending you promotional messages) in order
to verify your consent. You may revoke your consent at any time (this will not affect the processing
of your information undertaken until the revocation). If you want to stop receiving promotional materials,
etc., you can do so at any time as outlined in the
Your Choices section above.
Additional use of information
or when we have obtained your consent.
Legal Basis for Processing under the GDPR
In this section we provide information on the legal basis for our processing of your information:
When you register for an event, an account, or with our Services, such processing is necessary for the performance of our
When we collect precise location data following your prior consent, we process such data on the basis of your prior consent.
In other cases where we process your location data without consent, for example in order to provide
our Services, such as is necessary for the performance of our Services.
When you communicate with us or sign up for promotional materials, we process such data on the basis of our legitimate interest,
and our legitimate interest is to provide you with our promotional messages. Where we are required
under applicable local law to obtain consent for sending you marketing information, the legal basis
is your consent.
When you participate in special activities, offers, promotions, or programs.
We process such data on the basis of our legitimate interest, and our legitimate interest is to provide you with our promotional
When you engage with our online advertising and we actively collect your information in this context, we process such data
on the basis of our legitimate interest, and our legitimate interest is to provide you with our promotional
When you access third party products and services and we obtain information about you from such third-party sources:
We process such data on the basis of our legitimate interest, and our legitimate interest is to enhance your experience and
to improve our Services.
When you connect with us through social media:
Where we collect your consent in such case, for instance for marketing purposes, we process such data on the basis of your
Where we do not collect your consent in such case, we process such data on the basis of our legitimate interest, and our
legitimate interest is providing you with better Services and to enable you to use the full range
of our Services.
When we collect data from third parties or publicly-available sources:
For information which we need in order to perform the Services, such processing is necessary for the performance of our Services.
With regard to other information, we process such data on the basis of our legitimate interest, and our legitimate interest
is providing you with better Services and to enable you to use our Services more efficiently.
When we leverage and/or collect cookies, device IDs, location data, data from the environment, and other tracking technologies,
we process such data on the basis of your consent, and based on our legitimate interest, where we
do not obtain your consent and our legitimate interest is to provide you with better Services or
When we aggregate or centralize data, such processing is either necessary for the performance of our Services, or we process
such data on the basis of our legitimate interest, and our legitimate interest is to provide you
with better or customized Services and marketing.
When we provide you geographically relevant Services, offers, or advertising:
Where we collect your consent in such case, we process such data on the basis of your prior consent.
Where we do not collect your consent in such case, for such data that we need in order to perform the Services, such processing
is necessary for the performance of our Services.
Where we do not collect your consent in such case and where we do not need such data in order to perform the Services, we
process such data for our legitimate interest in offering you marketing and improving our Services.
When we disclose information to our affiliates and partners, and to our service providers and vendors:
Where we collect your consent in such case, we process such data on the basis of your prior consent.
Where we do not collect your consent in such case, such processing is necessary for the performance of our Services, or we
process such dad on the basis of our legitimate interest, and our legitimate interest is to provide
you with better Services and marketing.
When we process or share information in the event of an actual or contemplated sale, we process such data for our legitimate
interest in offering, maintaining, providing, and improving our Services.
When we conduct analytics, we process such data on the basis of our legitimate interest, and our legitimate interest is to
enhance your experience and to develop and improve our Services.
When we investigate suspected illegal or wrongful activity, we process such data on the basis of our legitimate interest,
and our legitimate interest is to ensure compliance with legal requirements and law enforcement requests
and for public safety purposes.
Right to lodge a complaint before the Data Protection Authority
We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the
right to lodge a complaint with a competent data protection supervisory authority, in particular in the
EU Member State where you reside, work or the place of the alleged infringement. You have the right to
do so if you consider that the processing of information relating to you infringes applicable data protection
How to contact us or our Privacy Office
In case of questions about the processing of your information please contact us at