Effective date: 2023 April 21st
Our privacy practices are subject to the applicable laws of the places in which we do business, so we have added region-specific terms that only apply to customers located in certain geographic regions, or as required by applicable laws.
- Scope of this Notice
- Personal Data We Collect and How We Use It
- Personal Information You Give Use
- Personal Information We Derive Through Your Use of Our Platform
- Personal Information We Collect From Third Parties
- What We Do With Your Personal Information
- Our Legal Grounds for Processing Your Personal Information
- Our Sharing of Your Personal Information
- Publicly Posted Content
- Data Retention
- Data Security
- International Data Transfers
- Your Privacy Rights and Choices
- Children’s Data
- Jurisdiction-Specific Privacy Disclosures
- Changes to this Notice
- Contact us
Scope of This Notice
- Create and maintain an account on our Platform;
- Visit a site residing on the Platform;
- Make a payment through Decolonizing Therapy;
- Attend a virtual event or webinar hosted by us, or otherwise engage with our interactive or pre-recorded content;
- Make a purchase or other transaction with us;
- Subscribe to or engage with our newsletters or other electronic communications;
- Interact with our social media pages;
- Click on our ads posted on third-party sites;
- Communicate with our customer support representatives or features (including via chat functions, email, text, or phone);
- Use our Platform; or
- Third-Party Sites. Websites, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us. Linked Sites have their own personal information collection and use practices, and we are not responsible for those practices. We encourage you to read each Linked Site’s privacy disclosures to understand how your personal information is processed.
- Personal Information We Process for Customers. Decolonizing Therapy website and courses are hosted through Kajabi (https://kajabi.com/policies/privacy ) which acts as a processor of personal information for its customers, and others. As a Decolonizing Therapy customer our respective privacy policies or notices govern our collection only and use of the personal information for which we are the controller. Any questions or requests relating to this data collection should be directed to [email protected].
- Workforce Members and Candidates. Our processing of the personal information of job applicants/candidates and workforce members is not governed by his policy. That processing is described in our Candidate Privacy Notice.
- Non-Personal Information. Our processing of information that cannot be linked to an identifiable or identified individual. We may process this data for any legitimate business purpose.
Personal Data We Collect and How We Use It
The personal information we collect about you depends on the nature and context of your interaction with our Decolonizing Therapy and our Platform. It may also depend on various choices you make about how to use the Platform we offer, the functionality and features you choose or enable, your location, the devices you use to interact with our Platform, and applicable law. The following describes the personal information we collect about you and the way we collect it.
Personal Information You Give to Us
We may collect the following categories of personal information you provide to us, including the following:
- Your Personal Details. For example, your first and last name, email address, phone number, physical address, job titles, and other contact information you provide.
- Account and Other Identifiers. For example, a username, screen name, handle, account ID, assigned user ID, customer number, or similar identifier that can be used to identify a user or account.
- User Content. For example, emails and text messages, photos, videos, audio recordings, customer support communications, comments/feedback, and any other content submitted by you.
- Survey Data. We may contact some individuals to request participation in a survey or other general research. If you choose to take part in these, you may provide personal information, in or along with your survey responses, or in any other feedback or comments you give us.
- Contests, Sweepstakes, and Prize Drawings Data. If you take part in a contest, sweepstakes, or prize drawing, then you may provide personal information, feedback, or comments to enter, or as part of the contest, sweepstakes, or prize drawing.
- Messages and Email Data. We collect information about you when you send, receive, open, read or otherwise engage with messages, email, or other communications in connection with our Platform, including whether you have opened or acted on those communications.
- Social Media Content. For example, interactions with our social media pages and content you post on them. If you use a social media provider to register or login to your Decolonizing Therapy account, we will receive your personal information from them.
- Other Personal Information You Provide. If you provide us personal information other than that described above, we will collect it and use it for the purposes for which you provide it or other consistent purposes.
- Inferences. In certain instances, we may infer personal information about you based on the information you have provided to us or that we have collected about you.
- Chat Modules. We may collect certain categories of personal information from you when you use our interactive chat module. By interacting with the chat box, you consent to our collection practices and understand and acknowledge that we may use this data to communicate with you about our Platform.
- Payment Processing Information. For example, the form of payment, payment card number and details, bank account number, payment service provider, and other payment information you provide.
- Demographic Information. For example, information that reveals your racial or ethnic origin, religious or philosophical beliefs, union membership, political opinions, or sex life or sexual orientation.
- Precise Geolocation. You may choose to grant our Platform permission to access your device’s precise geolocation, which we may use to confirm your address and help us operate or personalize our Platform, including by tagging posts, providing information on or adding information to a map, and helping us show you more relevant content or ads.
Personal Information We Derive Through Your Use of Our Platform
Kajabi permits third parties to use tracking technologies on their websites for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, and provide metrics on advertising effectiveness. The third parties use their technology to provide advertising about products and services tailored to your interests which may appear either on any of the Kajabi websites or on other websites.
The information we collect using these technologies includes:
- Device and Browser Identifiers. For example, an assigned user ID, IP address, or similar identifier that can be used to identify your device.
- Coarse Location Information. A general approximation of your location that is not based on global position system (GPS) information.
- Browsing and Search History. Information about the content you view and searches you make on the Decolonizing Therapy Site.
- Website Log and Usage Data. Information related to our pages you viewed, the services and features you used or interacted with, your browser type and details about any links or communications with which you interacted.
- Advertising Metrics. Information about the advertisements you have viewed on our Website.
Because the “Do Not Track” browser-based standard signal has yet to gain widespread acceptance, our Website(s) currently does not respond to those signals.
Personal Information We Collect From Others
We mostly collect personal information directly from you or based on your interaction with the Decolonizing Therapy Site. However, we also may collect personal information from third-party sources. These include Heroes, your colleagues, employers, business representatives, our Business Services Providers, Marketing and Advertising Providers, government entities, our Decolonizing Therapy affiliates, security services providers, other individuals, social media platforms, and other users of our Platform.
Even if you aren’t a registered user of our Platform, your information might still be collected. Some users may choose to share information about their contacts, including their name, email address, phone number, or other information. Users may also post or comment with personal information about other users.
Decolonizing Therapy uses Google’s Application Programming Interface (API) Services to enable the use of certain Platform features (i.e. use of your Gmail account to calendar events from the Platform’s Coaching feature). Decolonizing Therapy’s use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The information collected and used with these API services includes personal data such as email addresses, calendar information, and first and last names. Your Google information is used by the Kajabi system developers to provide or improve user-facing features that are prominent to your user experience.
What We Do with Your Personal Information
We may use your personal information for a variety of reasons. Depending on how you interact with our Platform, these include using personal information:
- Delivering Our Platform to you and providing related customer support, communication, and security.
- Policy Enforcement, including enforcing our terms of service, acceptable use policies, anti-spam policies, and similar policies.
- Advertising & Marketing to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
- Contextual and Behavioral Targeting to provide contextual customization of ads shown as part of an interaction with our website or application, using tracking technologies like cookies and pixels.
- Counting Ad Impressions & Website Interactions to audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify the position and quality of ad impressions, and perform similar activities.
- Customer Service to provide customer service, maintain and service products and accounts, provide training for quality assurance purposes, and perform similar activities.
- Fraud Prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
- Processing Transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility promotional benefits, and perform similar activities.
- Defending Against Claims & Litigation to defend against or respond to potential or actual claims and litigation.
Our Legal Grounds for Processing Your Personal Information
When we process personal information about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through whom you use our offerings, failure to provide such information may prevent or delay our fulfillment of these obligations.
To the extent required by applicable law, we will collect your personal data with your consent, where required, and in accordance with our legitimate need to provide our Platform.
Under European data protection laws, Decolonizing Therapy is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.
- Performing our Agreement. Decolonizing Therapy processes your information as is necessary to perform our contract(s) with you, including, without limitation, our Terms of Service and Decolonizing Therapy Payments Terms of Service, as applicable. For example:
- We use your information to create your account and set you up as a registered user on Decolonizing Therapy.
- We transfer your information outside of the EU to the United States to provide our Platform.
- Your Consent. Decolonizing Therapy processes certain information based on your consent, which you may revoke at any time. For example:
- Where you choose a method of verification to confirm your address, we do so in accordance with your consent.
- If you decide to use location services in the context of Decolonizing Therapy, we collect and process such location information based on your consent.
- We rely on your consent to tailor ads based on your activity and information on other websites and partner data, such as inferred interests.
- We will send you marketing communications where you have consented to receiving such communications in accordance with applicable law.
- Legal Obligation. Decolonizing Therapy may process your information to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:
- We may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g., a subpoena, search warrant, court order, or other binding request from government or law enforcement).
- We may retain and process your information where it is necessary for compliance with applicable tax laws.
- Vital Interests. Decolonizing Therapy may process your information in certain circumstances when it is necessary to protect your vital interests, or those of others. For example:
- We may need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person or the general public.
- We may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat.
- We may share your personal data with disaster relief agencies, first responders and other individuals to facilitate disaster or emergency response efforts.
- Legitimate Interests. We may process your information where it is necessary for the purposes of Decolonizing Therapy’ or a third party’s legitimate interests, such as those of Creators. We process your information in furtherance of the following legitimate interests:
- Providing, improving, and developing our Platform. We use your information to provide our Platform, including any personalized services, and to understand and improve our business and our user relationships.
- Providing ads, and measurement and analytics services. We use your information to provide personalized ads both on and off Decolonizing Therapy and to measure and analyze the success of those ads to provide accurate and reliable reporting to our advertisers. We do so as necessary to pursue our legitimate interests in marketing and monetizing our Platform.
- Sending marketing communications. We rely on our legitimate interests in marketing and promoting our Services to use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.
- Sharing information for legal and safety reasons. Where required for legal and safety reasons, we may disclose information to law enforcement and related agencies and authorities in furtherance of the legitimate interests described further below.
Our Sharing of Your Personal Information
We DO NOT share your personal information with the following:
Other Content Providers.
Business Services Providers.
Marketing and Advertising Providers.
We will only share information with the following under extenuating circumstances:
Legally Required Parties/Governmental Entities. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
Reorganization. Persons involved in the consideration, negotiation, and completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
Authorized Disclosures: To any party when authorized by the individual to whom it pertains to share it.
Publicly Posted Content
Decolonizing Therapy users may have the ability to post content to one or more Decolonizing Therapy forums, such as chat rooms and bulletin boards. You should be aware that when you voluntarily disclose personal information in any forum, 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. You may request and obtain the removal of such posted content by contacting us at support@Decolonizing Therapy.com and specifically identifying the content to be removed. Please be advised that any such removal does not ensure the complete or comprehensive removal of all traces of the content posted on the Decolonizing Therapy forums.
We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply common protections described in this policy. These protections align with well-known standards such as ISO 27001:2017 and others.
We have and never will sell or trade any of our customer information.
No part of your financial information is ever stored on any computer with an outside connection to a publicly accessible network (Internet). Decolonizing Therapy LLC does not store any financial information of our customers. We do, however, store contact information (excluding financial information) and take the utmost caution to ensure its privacy.
International Data Transfers
We are located and operate in the United States. By submitting personal information to us, you understand that we may transfer your personal information to a country foreign to you, including the United States, for processing. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service providers located in foreign jurisdictions. Whenever we engage a service provider, we require that its privacy and security standards adhere to our requirements and applicable privacy laws.
Your Privacy Preferences
You can control the collection and use of personal information for some of our processing activities. This includes:
- Adjusting Communication Preferences
Emails From Decolonizing Therapy. During the registration for Decolonizing Therapy, you were presented with an opt-in to receive email communications. If you wish to no longer receive email communications, you can click on the “unsubscribe” link located at the bottom of the email, email Decolonizing Therapy at [email protected] to let us know, and we will remove you as soon as possible. Opting out of marketing or newsletter emails will not opt you out of all emails—we may need to send you transactional or similar emails related to your Decolonizing Therapy account, purchases, legal or contractual updates, or similar topics. You are not able to opt out of these emails.
Emails from Third Parties. During registration for a Decolonizing Therapy virtual event or webinar, you may be asked to opt-in to receive emails from third parties. If you choose to opt-in to receive email communication from a third party, you can opt out or unsubscribe at any time by clicking on the “unsubscribe” or similar opt-out link in the third party’s’ email communication. Opting out of marketing or similar communications from third parties may not prevent all emails from third parties. Third parties have their own privacy policies regarding the personal information they collect and process about you. We urge you to review their privacy policies regarding their processing of your personal information.
- Blocking Cookies
Most web browsers automatically accept cookies by default, but you can alter how your browser responds to cookies by adjusting the settings. Information about managing cookies for popular web browsers can be found in the links below:
Many websites, including ours, employ Google Analytics. To opt out of Google Analytics data collection, follow these instructions from Google.
Your Privacy Rights
Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include the following:
- Access and Portability. The right to know (or confirm) what personal information a business has collected about you, and to receive a copy of it.
- Deletion/Restriction. The right to request that a business delete personal information it has collected from you or restrict how it is used, subject to certain exceptions.
- Correction/Rectification. The right to request correction of inaccurate personal information maintained by the business.
- Opt-Out of the Sale/Sharing of Your Personal Information. The right to opt out of the sale of your personal information to third parties. The term “sale” varies by jurisdiction, but sometimes includes the right to opt out of the use of personal information for targeted advertising purposes.
- Revoke Consent. Where consent is required for processing under applicable law, you may withdraw your consent to the processing of your information at any time.
- Object to Processing. Object, on grounds relating to your situation, to our processing of personal data concerning you which is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) processed by us on the basis of our legitimate interest. In this case, where applicable, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
- Limitation/Restriction. The right to limit or restrict a business’s use or disclosure of certain personal information.
- Opt-out of Profiling/Automated Decision-Making: The right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.
- Complaints. The right to lodge a complaint with the appropriate governmental authority.
Decolonizing Therapy will honor the privacy rights afforded to individuals in accordance with applicable law and will not discriminate against individuals for exercising their privacy choices under the law.
Exercising Your Privacy Rights
You may make a request at any time to exercise your access, deletion, correction, and restriction rights listed above by using our “Do Not Sell or Share” or “Data Rights Request” at the bottom of Decolonizing Therapy.com, or emailing us at [email protected] . We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.
The Kajabi Platform is not intended for persons under 16 years of age. We do not knowingly collect or process the personal information of individuals under the age of 16. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us their Personal Information, please contact us at [email protected] .
Jurisdiction-Specific Privacy Disclosures
We are committed to openness and accountability with respect to how we handle your personal information pursuant to Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including:
- The Personal Information Protection and Electronic Documents Act (PIPEDA)
- Alberta’s Personal Information Protection Act (Alberta PIPA)
- British Columbia’s Personal Information Protection Act (BC PIPA)
- Québec's Act respecting the protection of personal information in the private sector (Québec Act).
Consent. Where you have provided your consent to the collection, use, and transfer of your personal information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by contacting us at [email protected] . Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
Use of Your Personal Information. We will not collect, use, or disclose personal information except for the identified purposes identified above (See What We Do with Your Personal Information), unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the personal information we provide to them, we ensure that an agreement is place the ensure compliance with applicable Canadian Privacy Law.
Exercising Your Canadian Privacy Rights. If you have an account with us, you may view and update your account information (as noted above) directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your personal information, you may submit a request using our “Do Not Sell or Share” or “Data Rights Request” at the bottom of Decolonizing Therapy.com, or emailing us at [email protected] . When submitting a request, we may require that you take additional steps to validate your identity or legal authority. We will begin processing your request once you have completed the verification process.
We have put procedures in place to receive and respond to inquiries about our policies and practices relating to the handling of personal information. We will provide a response to any personal information request within the timeframe required by law. If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation.
Additional information about how to exercise your rights under Canadian Privacy Law can be found here:
Office of the Privacy Commissioner of Canada
Office of the Information and Privacy Commissioner of Alberta
Edmonton office: (780) 422-6860
Calgary office: (403) 297-2728
Office of the Information and Privacy Commissioner of British Columbia
Vancouver: (604) 660-2421
Elsewhere in BC: (800) 663-7867
Commission d’accès à l’information du Québec
- Members of the European Economic Area and the United Kingdom
You may lodge a complaint with a supervisory authority at any time if you are of the opinion that the processing of personal data relating to you violates applicable law. If the complaint relates to provisions of the EU and UK GDPR, you can lodge such complaint with a supervisory authority in the Member State of your place of residence, your place of work or the place of the alleged infringement. You may identify the applicable supervisory authority based on your location on the European Data Protection Board website. If the complaint relates to provisions of the UK GDPR, you can lodge such complaint with the Information Commissioner’s Office. For contact details of your local Data Protection Authority, please see: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
European Data Protection Office (EDPO)
Avenue Huart Hamoir 71, 1030 Brussels, Belgium
Email: [email protected]
Online request form: https://www.edpo.brussels/contact
8 Northumberland Avenue, London WC2N 5BY, United Kingdom
Online Request Form: https://edpo.com/uk-gdpr-data-request/
If you have complaints about our privacy practices, please contact us using the contact methods provided. We will evaluate any complaints and determine if further action is necessary and keep you informed of our investigation and decisions. If you remain dissatisfied with our handling of a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
- U.S. State-Specific Privacy Rights
Residents of certain U.S. States have the rights indicated below as of the date in which the applicable laws granting such rights are effective, which are as follows:
California: January 1, 2023
Virginia: January 1, 2023
Colorado: July 1, 2023
Connecticut: July 1, 2023
Utah: December 31, 2023
Decolonizing Therapy does not engage in automated decision making/profiling so no action is required to exercise this right under state law.
If you would like to opt-out of the Kajabi sale or sharing of your personal information for cross-contextual behavioral or targeted advertising, please click the Do Not Sell or Share My Information link.
You may make a request at any time to exercise your privacy rights under applicable law by using our “Data Rights Request” or “Do Not Sell or Share My Information” links at the bottom of https://www.kajabi.com. Kajabi has stated they will respond to your request within 45 days of receipt (if properly submitted). If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. In all cases we will complete your request within 90 days from the date of our receipt of your properly submitted request. If we decline to act regarding your request, we will inform you of our decision and the reason for it, along with instructions on how you may appeal our decision.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
CHANGES TO POLICY
Email: [email protected]
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