Privacy Policy

PRIVACY POLICY

Last Modified: September 2, 2020

This privacy policy (“Privacy Policy”) provides information on the collection, use, sharing and processing of personal information by Explore Freedom Ltd t/a Nefe Oguntoye ( hereinafter variously, “Company”, “we”, “us”, or “our”) in connection with your use of the Company’s website, platforms, courses and any sites the Company may have now or in the future as well as your interactions with the Company during any in-person meetings or events, and your use of any products or services offered by the Company (collectively, the “Services”).  This Privacy Policy explains the choices that you have in relation to these processing activities.

YOUR CONSENT 

By using our Services in any manner or disclosing your information to us, you consent to our collection and use of your personal information as described in this Privacy Policy.  If you do not accept this Privacy Policy or do not meet or comply with the provisions set forth herein, then you may not use the Services. If required by applicable law, we will seek your express consent to process personal data (i) provided by you and/or (ii) collected during your use of the Services.  Any consent shall be entirely voluntary.  In the event you do not provide consent to use or process your personal data, then you may not access and/or use the Services.

CHANGES TO PRIVACY POLICY

To comply with legal requirements or to meet changing business needs, this Privacy Policy may change over time.  However, we may update this Privacy Policy at any time, with or without advance notice, so please review it periodically.    We will update the ‘Last Modified’ date above and may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. By way of example, if there is an important change that we want to highlight to you, we may inform you through another appropriate way (i.e. pop-up notice or statement of changes on our website or via email).  You can determine when this Privacy Policy was last revised by referring to the date it was “Last Modified” above.  Your continued use of the Services after any modification to this Privacy Policy will constitute your acceptance of such modifications and/or updates.

WHO IS RESPONSIBLE FOR YOUR INFORMATION?

Unless an exception is identified, the Company is responsible for processing your personal information described in this Privacy Policy.

WHAT INFORMATION DO WE COLLECT?

When you use the Services, you may provide the Company with two main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you browse and use the Services. We collect information from you when you (a) use and/or access the Services, (b) register an account and/or subscribe to the Company’s courses, (c) open and/or respond to our emails, (d) contact the Company, and/or (e) visit any page online that displays our content, (f) make purchases or register through the Services, and/or (g) provide information to any of our customers, partners, and/or other users.

We collect and process the following information about you both online and offline.

  • Offline information about you originates from our interactions with you during in-person meetings, or at Company events, conferences, workshops or gatherings.
  • Online information about you originates from your activities on our Services, information provided by third party sources, such as data aggregators who may not have a relationship with you, and use of cookies and similar technologies.

Personally Identifiable Information You Choose to Provide

We may ask for certain personal information from you for the purpose of providing to you content and/or services that you request.  We collect personal information such as: (i) your personal and/or business contact information (including name, telephone number, email and address, and business website address); (ii) Company name and title; (iii) your financial information (such as checking account information, credit card number, expiration date, verification number, and billing address); (iii) username and password, if applicable; (iv) location information; and/or (v) preferences, behavior and testimonials.  Once you register, you have opted in to receive electronic communications from the Company.  The Company may also provide you with the opportunity to participate in surveys through the Services.  If you participate, we will request certain personally identifiable information.  Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.

Information We Collect Automatically

Cookies:  We use Cookies, tracking pixels, and related technologies to recognize you and your device.  Cookies are small text files that contain a string or characters and uniquely identify a browser on a device connect to the Internet.  Any browser visiting our site will receive cookies from us.  In an effort to be transparent with our data collection practice and the technologies we use to provide the Services, please review our we use Cookies in our Cookies Policy, which set forth how to manage and remove Cookies, and related use on our Services.

Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.

Aggregate:  We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on, system configuration information, and/or other interactions with the Services.  This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual.

Analytics:  We use analytic software to gather statistics and usage trends for product and service improvement purposes.  The Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.

Third Party Services:To support the services we provide to you; we may use services hosted by third parties.  These services may collect information sent by a browser as part of a web page request, including ‘Internet Protocol’ addresses, browser software, and/or clickstream patterns. If such third-party services collect information, they do so anonymously without identifying individual visitors.  However, we may link the information we record using tracking technology to personal information we collect.  In addition, we may allow third parties who list services to use Cookies in connection with your use of the Services.  They may collect and store the same type of information and use it similarly to the Company, as described above.

Site Information:  We collect information related to course enrollments, course usage and other transactional data, including without limitation product and/or service orders.  We also collect data in the event you respond to a survey or submit publicly available information, such as through your social media posts. In the event you respond to us or submit requests through our Services, we may retain the content of your messages together with our responses to your requests.

WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

We use information collected as described in this Privacy Policy to provide you with the Services and/or the information and/or content that you have requested, and, in some cases, to contact you about our products, features and/or other services.  We also use the information collected to take the following actions:

  • Engage in transactions with you to process orders for the Company’s products or services;
  • Administer your course;
  • Communicate and respond to requests and inquiries to the Company;
  • Operate, maintain and improve the Services including;
  • Communicate with you about your course progress;
  • Personalize your experience with the Company;
  • Notify you about important information, new services, and special offers we think you will find valuable;
  • Deliver functionality on our Services;
  • Analyze, develop, improve, and optimize the use, function, design and performance of our Services;
  • Manage the security of our site, networks and systems;
  • Comply with certain laws and regulations; and
  • use information for other purposes about which we notify you.

The information collected in the aggregate enables the Company to better understand your use of the Services and to enhance your enjoyment. We may use financial information to process payment, enroll you in one of our courses and/or other related services in which you elect to participate.  If you use the Services, you agree to receive certain communications from us including but not limited to the following:

Special Offers, Newsletters and Updates.  We will occasionally send you information on products, special deals, promotions and newsletters. You can sign up for these emails from us at any time. Out of respect for your privacy, you may elect not to receive these types of communications by contacting us or replying to our emails.

Blogs.  Our Service may have links or access to publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

Customer Service.  Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect.

For any personal information collected about you in the EU, our basis for processing is the following:

  • In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information;
  • In order to engage in transactions with customers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you;
  • We process personal information for marketing and sales activities based on your consent, where so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services;
  • We rely on our legitimate interest to analyze, develop, improve and optimize our sites, products and services, and to maintain the security of our sites, networks and systems; and
  • In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

HOW LONG DOES THE COMPANY RETAIN PERSONAL INFORMATION?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.  In some circumstances we may anonymize your personal data (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.

The Company maintains personal information for the following retention periods:

  • If you have registered for a Company account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for twenty-four (24) consecutive months.  The Company retains records of that deletion for a period of thirty (30) days;
  • If you have registered for our newsletters or blogs, your subscription data will be retained for as long as you are subscribed or on our distribution list. The Company retains records of that deletion for a period of thirty (30) days; and
  • Contact information such as your email address or phone number collected online and offline during our interactions with you will be maintained for as long as we have an active relationship with you. We treat you as having an active relationship if: (1) you have interacted with the Company or updated your contact details or preferences within the last twenty-four (24) months and (2) you have not made a deletion request.

Please be aware that even after your request for a change is processed or following termination and/or deactivation of your account, we may, for a time, retain residual information about you in its backup, audit and/or archival copies of its database, and reserve the right to access and utilize collected user data in the future.  Please be aware that we may still email you non-commercial emails related to your account and your transactions through the Services.  In some cases, if you choose not to provide the Company with requested information, you may not be able to use and/or access all of the Services.

WHEN AND HOW WE CAN SHARE YOUR PERSONAL INFORMATION?

Service Providers:  We may share your personally identifiable information as well as information from tools like Cookies, log files, and device identifiers and location data (such as usage data, referring/exit pages and URLs, platform types, number of clicks, etc.), with employees, contractors, and/or agents that help the Company provide the Services to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services (including without limitation credit card processing services, order fulfillment, analytics, event/campaign management, website management, information and relate infrastructure provision, customer service, auditing and similar services).  We strive to use commercially acceptable means to protect your personal information. If Service Providers acquire confidential or proprietary information belonging to the Company or its customers, such information is required to be handled in confidence and may not be disclosed to unauthorized third parties. Service Providers who violate our security and safe maintenance of data policies are subject to appropriate discipline including, but not limited to, termination. We will not share your personally identifiable information in ways unrelated to those described in this Privacy Policy without providing you with an opportunity to opt out of such use or otherwise prohibit such unrelated use. We encourage our Service Providers to adopt and post privacy policies; however, such Service Provider’s use of personally identifiable information obtained through the Company is governed by such Service Provider’s privacy policies and is not subject to our control. Certain Service Providers will automatically collect non-identifying information about your use of the Services by using Cookies and other technologies as similarly used by the Company.

For Collaboration: We may share your information, including when you choose to use certain features in the Services that by their nature support sharing with third parties who you choose. Your name, email address, and any content you choose to share will be shared with such third parties, and such third parties may communicate with you in connection with your use of the Services.   Additionally, if you request or authorize us to share your information, we will do so in such circumstances.

Compliance with Laws: The Company will not disclose your personal information to third parties except as set forth in this Privacy Policy and in the following circumstances: (i) to investigate and defend the Company’s members against any third party claims and/or allegations and/or otherwise to protect the Company from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities or to identify, contact, or bring legal action against someone who may be violating our contracts, policies, or procedures, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services and/or (v) to protect the security and/or integrity of the Service.

Business Transfers: If we sell or otherwise transfer part or all of the Company or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation or similar proceedings), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.

General:  Your personal information may be shared if it is made anonymous and aggregated, as in such circumstances the information ceases to be personally identifiable data.  We do not provide personal information to companies for the purpose of independent telemarketing, email marketing, or direct mail marketing of any products or services of those companies.

HOW IS YOUR PERSONAL INFORMATION SECURED?

The Company has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process.  We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We maintain security standards and procedures to help prevent unauthorized access, loss, misuse, alteration, disclosure, or destruction of confidential information about you.  All sensitive/credit card information you supply is encrypted via Secure Socket Layer (SSL) technology.  We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. While we strive to secure your information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control. Please do your part to help the Company.  You are responsible for maintaining the secrecy of your account information, and for controlling access to emails between you and the Company, at all times.  Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing the Services.   We are not responsible for the functionality, privacy and/or security measures of any other organization.

WHAT ARE YOUR CHOICES?

Your Information Choices

We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information.  Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to us, and you can limit the communications that we send to you. You have the choice to exercise any of the following choices:

  • Opt-out of use of your personal information: You may withdraw consent that you have previously provided for the processing of information about you;
  • Delete personal information: You can ask us to erase or delete all or some of the information about you;
  • Change or correct personal information: You can edit some of the information about you by either 1) submitting changes through the “manage subscription” link in the footer of your email; 2) replay to any email sent by us and ask for changes; or 3) You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate by sending an electronic request to nefe@explorefreedomnation.com;
  • Object to, limit, or restrict use of personal information: You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate); and
  • Right to access or have your personal information provided to you. You can also ask us for a copy of information about you and may ask for a copy of information about you provided in machine readable form if you reside in the EU, other country or state that provides you this right as a matter of applicable law.

You can exercise these choices by contacting us at nefe@explorefreedomnation.com.

Your California Privacy Rights

Under California Consumer Privacy Act (“CCPA”), California residents are entitled to receive the right to access and obtain a copy of your personal information. You may write us and ask for records of any and all personal information. The CCPA requires businesses to disclose (1) the categories of personal information the business collected about Individuals, (2) the categories of sources from which personal information is collected, (3) the business or commercial purpose for collecting or selling personal information, (4) the categories of third parties with whom the business shares personal information, and (5) the specific pieces of personal information the business has collected about the Individual. To obtain such information from the Company, please email your request to nefe@explorefreedomnation.com and we will provide a list of categories of personal information disclosed within thirty (30) days of receiving such a request.  This request may be made no more than once per calendar year.  We reserve the right not to respond to requests submitted in ways other than those specified above. The following exceptions may prevail with respect to fulfillment of data access requests: (a) the Company may not provide personal data to an Individual, if management determines that we cannot identify the Individual in our systems because the data we have has been de-identified to the extent that identification is not possible; and/or (b) the Company may not provide personal data to an Individual, if the Individual is involved in a civil or criminal proceeding with the Company.

Data Protection Rights for EU members.  For purposes of the applicable data protection laws (the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), we would like to make sure you are fully aware of all of your data protection rights. Under the GDPR, you have various rights in relation to your personal information, such as the rights of access and receive copies of personal information, rectification whereby you may ask us to correct any information which you believe is inaccurate, restriction rights to request restrictions on processing of your personal data under certain circumstances, objection of processing certain personal data, portability rights to request that we transfer data to another organization, and erasure rights to request that the Company erase certain personal data. Please note that these rights are subject to certain limitations set forth in applicable law.  To exercise these rights, please contact our

To exercise these rights, please contact our data protection officer at nefe@explorefreedomnation.com.  We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of applicable laws. Please note that we may keep a record of your communications to help us resolve any issues you raise.  If you make a request, we have one month to respond to you.

DO WE COLLECT SENSITIVE INFORMATION FROM CHILDREN?

The Company does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information, please contact us at nefe@explorefreedomnation.com. By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Services.

HOW WE USE OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites and/or services linked to and/or from the Services, including the information and/or content contained therein. Please remember that when you use a link to go from the Services to another website and/or service, our Privacy Policy does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on the Service, are subject to such third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your personal information. If you are using a third-party website and/or service and you allow them to access your personal information, you do so at your own risk.

WHAT LANGUAGE GOVERNS?

The governing language of this Privacy Policy is English, which shall prevail over any other languages used in any translated document.

HOW TO CONTACT THE COMPANY IF YOU HAVE QUESTION, COMMENTS OR COMPLAINTS 

If you have any questions, comments or concerns, please contact nefe@explorefreedomnation.com.

en_GBEnglish