GDPR Privacy Notice

Marie Forleo International, Inc. (“Marie Forleo”)
GDPR Notice
Effective Date: 19 September 2018

GDPR Privacy Notice

This GDPR privacy notice (this “GDPR Notice”) is included in our Privacy Policy and applies to the ‘personal data,’ as defined in the GDPR, of natural persons located in the European Economic Area (“EEA Individuals,” “you,” or “your”) processed by Marie Forleo. Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them in the Marie Forleo Privacy Policy or, if not defined herein or in the Privacy Policy, the GDPR. To the extent of any conflict between this GDPR Notice and any other provision of the Privacy Policy, this GDPR Notice shall control only with respect to EEA Individuals and their personal data. If you are located elsewhere, please see our Privacy Policy here.

Controller Disclosure & Details:  We are a data controller of personal data regarding the following categories of EEA Individuals: Visitors, Registered Users, and vendors (collectively, “Business Contacts”) for the purposes and under the legal bases described in the table below. Please note that, in some cases, the categories of data subjects above may overlap (e.g., Visitors and Registered Users using the Websites).

Data Subject Category Purpose & Legal Basis of Processing
General (applies to all data subjects below) Information Security: Our web servers will log your IP address and other information (e.g., browser information, operating system, request date/time, user agent string, referral and exiting URL) in order to maintain an audit log of activities performed. We use this information pursuant to our legitimate interests in tracking usage of the Websites, combating DDOS or other attacks, and removing or defending against malicious visitors on the Websites.
Business Contacts Direct Marketing: Generally-speaking, we will provide email marketing (e.g., our newsletter) pursuant to a Business Contact’s consent. In cases where a Business Contact buys, or enters into negotiation for the sale of, a product or service, email marketing shall be sent to such Business Contact pursuant to our legitimate interest in sending marketing communications to such Business Contacts in the context of a sale.

Rewards and Promotions: Our legitimate interest in administering our rewards and promotional offerings, such as with our third-party promotional and marketing partners.

Testimonials or Feedback: Our legitimate interest in using testimonials or feedback from Business Contacts for marketing purposes, such as posting on the Websites or within sales decks, pitches, or other promotional content (e.g., email marketing).

Executing Contracts and other Legal Documentation: We will process all personal data as necessary for the performance of contracts to which Business Contacts are a party (such as our Terms of Use or Privacy Policy) or to take requested steps to enter into such contracts, such as in order to deliver our products and services.

General Business Development: Our legitimate interest in furthering business relationships (such as by storing Business Contact information within a CRM or other database/file), ensuring customer satisfaction, and answering inquiries.

Audience Measurement and Retargeting: Pursuant to a Visitors’ consent, we use an assortment of marketing and analytics cookies for purposes of audience measurement, retargeting, and creating relevant Visitor experiences (such as based on their interaction with our Websites).

Controller’s Representative: Our representative in the European Union is:

ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany

https://www.eprivacy.eu  

Categories of Recipients: Marie Forleo personnel will process the categories of EEA Individuals’ (as listed above) information appropriately for sales, marketing, finance, and related purposes. Such EEA Individuals’ information (or a particular category of EEA Individual, as listed in the table above) is also disclosed to various categories of recipients to effectuate the purposes described in the table above, including companies providing technical assistance, order fulfillment, customer service, marketing assistance, payment processing, survey collection, promotional and marketing assistance, and business operations.

Retention:Marie Forleo retains your personal data as necessary to fulfill the purposes set forth within this Notice and to the extent you have (or demonstrate interest in) a relationship with Marie Forleo, unless you request deletion of such data or such data is no longer relevant. In some cases, we may have to retain data to comply with our legal obligations (e.g., accounting, finance, tax).

Your GDPR Rights: As a natural person, you have a right to: (i) request access to, correction and/or erasure of your personal data; (ii) object to processing of your personal data; (iii) restrict processing of your personal data; and (iv) request a copy of your personal data, or have a copy thereof sent to another controller, in a structured, commonly used and machine readable format under the right of data portability. You may exercise these rights and submit a GDPR complaint by contacting: info@marieforleo.com with the subject line “GDPR Notice.”  

You also have the right to lodge a complaint about the processing of your personal data with an appropriate data protection authority, and, as applicable, to exercise third-party beneficiary rights under Marie Forleo’s Standard Contractual Clauses.

Contact details for the EU data protection authorities can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Objecting to Legitimate Interest/Direct Marketing: You may object to personal data processed pursuant to our legitimate interest. In such case, we will no longer process your personal data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your personal data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to info@marieforleo.com with the subject line “GDPR Notice” (the latter for instances where, for example, you would not like to receive follow-ups from our sales team). In such case, your personal data will no longer be used for that purpose.

Transfer of Personal Data outside the EEA: We are self-certified under the EU-US and Swiss-US Privacy Shield for appropriate transfer of your personal data, such as to our US data centers, pursuant to Article 45(1); in these instances, you may have specific rights under the Privacy Shield. In other instances, however, we may alternatively rely on appropriate Standard Contractual Clauses to ensure adequate protection for your personal data.

Disclosure to Public Authorities: Marie Forleo may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Corporate Restructuring: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal data as set forth in this GDPR Notice. This GDPR Notice shall be binding upon Marie Forleo and its legal successors in interest.

Updates to this GDPR Notice: If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this GDPR Notice, and the “Effective Date” at the top of this page will be updated accordingly.

How to Contact Us: Please reach out to info@marieforleo.com for any questions, complaints, or requests regarding this GDPR Notice; please include the subject line “GDPR Notice.”