Privacy Policy

Welcome to AELYN. AELYN is an online course provider through its website aelyn.com.

OVERVIEW

This website is owned and operated by Empwr Inc. dba AELYN (“AELYN”), a Delaware corporation with offices at Newport Beach. This Privacy Policy (the “Policy”) applies to information collected on this Site and any AELYN website accessed via a user’s computer, mobile, e-reader, tablet or other device (“Device”) used to access the Devices, and applications and sites affiliated with AELYN products and services, that link to this Policy (collectively, the “Devices”). This Policy is incorporated into and subject to the terms of use and conditions for this Site (“Terms”). Each time that you access or use the Devices, you signify that you have read, understand and agree to be bound by the Terms and this Policy. If you do not agree to the Terms and this Policy, you must discontinue using our Devices. From time to time, AELYN may update its Policy. AELYN will post the new Policy with a new effective date to notify you of these changes. If you are concerned about how your information is used, you should check back to this Policy frequently for updates. By accessing the Devices after the Effective Date, you are deemed to consent to AELYN’s then-current Policy.

Part I of this Policy sets forth AELYN’s policy as to Personal Information collected online through the Site. Part II sets forth the Policy as to Personal Information collected other than from the Site. 

“Personal Information,” is any information that enables AELYN to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you. Personal Information includes “sensitive Personal Information” and “pseudonymised Personal Information” but excludes anonymous information or information that has had the identity of an individual permanently removed.

Your use of the Site and/or provision of your Personal Information or sensitive Personal Information to AELYN constitutes your consent to the use, storage, processing and transfer of that information in accordance with this Policy.

PART I – AELYN WEBSITE PRIVACY POLICY

Throughout the Site, there are forms for visitors to request information, products, and services. AELYN uses Personal Information from these forms to provide the information and materials you request.

Forms on the Site that request financial information do so in order to bill you for products or services ordered. Unique identifiers (such as your email) are collected from website visitors to verify the user’s identity for access to restricted content or features on the Site.

This Policy discloses AELYN’s privacy practices and contains detailed information about the following:

1. What information does AELYN collect?
2. What are “cookies” and how does AELYN use them?
3. Does AELYN share information with third parties?
4. How does AELYN use the collected information?
5. How can you review and modify your Personal Information?
6. What is the opt-out policy for the Site?
7. California privacy rights
8. What types of security procedures are in place to protect against the loss, misuse or alteration of your information?

1. What information does AELYN collect?
   AELYN collects the following Personal Information about site visitors:
2. a) Site Use Information. AELYN collects technical information relating to each time a visitor comes to the Site, including IP address, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform type (e.g. Internet Explorer browser on a Windows platform).

AELYN may also collect information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Gathering this technical information helps us to learn what browsers we need to support and helps us determine what sections of the Site are most popular and how many visitors come to the Site. You do not have to register with the Site before we can collect this information.

1. b) Information Provided to AELYN. You may provide Personal Information to us which may include your name, home and/or work email address, postal address, phone number and/or fax number, your employer and job title, demographic information about you including birth year and if you are making a purchase, your debit or credit card information. Such information is only required to take advantage of products and services provided through the Site.

AELYN collects Personal Information in the following ways from different parts of the Site:

• Membership Applications: You are sharing Personal Information with AELYN when you join or renew your membership through the Site. AELYN members will have AELYN membership log-in credentials which enable members to take advantage of restricted content and features on the Site.
• Other Registration: When registering for specific services AELYN may ask for the same type of Personal Information. For example, if you subscribe to an e-mail newsletter, we will ask you to provide your e-mail address.
• Online Purchases: When you make a purchase of AELYN course[s] through the Site, AELYN may also ask for the same type of Personal Information. The number and variety of useful products and services on the Site may require the collection of Personal Information. 
• Email Newsletters: When you sign-up to receive AELYN email information newsletters, AELYN may require that you supply your name, email address and other information.

2. Do we share information with third parties? Personal Information collected through the Site is generally collected and maintained solely by AELYN. AELYN may share Personal Information in the following ways:
3. a) Information You Give AELYN

(i) When you provide Personal Information about you on the Site to register for a service, buy a product, or take advantage of a promotion AELYN will share such Personal Information as necessary to the complete the transaction requested by you. AELYN also reserves the right to sell or otherwise provide to selected third parties, mailing/information lists derived from such registrations. These third parties may contact you directly regarding their products and services.?

If you wish to opt out of the sale/distribution of such lists to third parties at any time, you may do so by following the directions in Item 6 below. 

1. Information provided when joining or renewing membership in AELYN. If you join or renew your AELYN through the Site, you provide Personal Information about you on the membership application. AELYN will share such Personal Information as necessary to complete the transaction requested by you. AELYN also reserves the right to sell or otherwise provide mailing/information lists concerning members to selected third-parties.?

If you wish to opt out of the sale/distribution of such lists to third parties at any time during your AELYN membership, you may do so by following the directions in Item 5 below. 

1. b) Sensitive Personal Information. AELYN does not share with third parties, sensitive Personal Information such as passcodes, social security numbers, debit or credit card numbers except as necessary to complete transactionsrequested by you or to comply with legal obligations, under strict confidentiality and security protections; nor does AELYN publish such sensitive Personal Information.
2. How does AELYN use the collected information? AELYN uses your Personal Information according to the terms of the Policy in effect at the time of our use. We will only process your Personal Information, including sharing it with third parties, where (i) you have provided your consent which can be withdrawn at any time, (ii) the processing is necessary for the performance of a contract to which you are a party (including your membership with AELYN), (iii) is required by law, (iv) processing is required to protect your vital interests or those of another person, or (v) processing is necessary for the purposes of AELYN’S legitimate commercial interests, provided your interests and fundamental rights do not override those interests.

We use Personal Information for the following purposes:

1. a) Information You Provide to AELYN

1. to carry out AELYN’S obligations arising from your membership, and any other agreement entered into between you and AELYN
2. to update and renew your membership as required 
3. to provide you with the information, products and services you request from AELYN 
4. to arrange and deliver conferences, events and programming relevant to your subjects of interest
5. to respond to your questions and provide related membership or customer services
6. to improve the Site
7. to send you AELYN publications, information about member benefits and special offers, and other information that AELYN believes is relevant and useful to its members, where you have not opted out of receiving such information; we may automatically process your information to determine which products and services may be of most use to you. You may object to such processing by contacting us at team@beaelyn.com
8. to send you third party information that AELYN believes is relevant and useful to you, where you have given your consent
9. to notify you about changes to your membership or related services or to ask you to provide feedback 
10. to enable you to partake in a prize draw, competition or complete a survey
11. to administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
12. to comply with all applicable laws or legal processes, including providing information on individual users to the appropriate governmental authorities where required by law enforcement or judicial authorities including in matters involving a danger to personal or public safety, or to protect the rights, property or safety of AELYN members, customers or others, AELYN may voluntarily provide information to appropriate governmental authorities.

1. b) Site Use Information. As mentioned above, AELYN uses the aggregate, anonymous data collected to let our sponsors/advertisers know the number of impressions or views and the number of “click throughs” on their advertisement(s).

AELYN also uses this aggregate, anonymous data to perform statistical analyses of the collective characteristics and behavior of visitors to the Site; to measure user interests regarding specific areas of the Site; and to analyze how and where best to use our resources.

Without such data, we would not know which parts of the Site are the most popular, and we would not be able to change and update the content and services appropriately.

1. c) Exceptions. On occasion AELYN collects Personal Information through the Site with the intent to afford a greater degree of privacy for such information than is otherwise set forth in this privacy policy. 

In those relatively rare situations where AELYN does so it will clearly disclose to you at the time it collects such information, what degree of privacy will be afforded to the Personal Information collected at such time; and AELYN will follow a process to assure that the specifically disclosed degree of privacy is in fact afforded to such information. 

For example, AELYN may collect survey information through a survey where AELYN’s use of any Personal Information from that survey is more limited than the general AELYN Privacy Statement would otherwise allow; in such a case, AELYN will disclose the stricter privacy policy governing that survey information at the time such Personal Information is collected from the survey respondent.

4. How can you review and modify your Personal Information? You have the following options for modifying or causing to be deleted Personal Information or demographic information previously provided by you to AELYN by sending an email to: team@beaelyn.com.
5. What is the opt-out policy for this Site? AELYN provides members and customers with the opportunity to opt-out of receiving communications from AELYN. If you no longer wish to receive specific communications or services, send an e-mail to: team@beaelyn.com.
6. California Privacy Rights and California Consumer Privacy Act (CCPA) of 2018.AELYN may disclose your Personal Information to its subsidiaries or other third parties who may use that information to market directly to you. As a California resident, you have the right to opt-out of having your Personal Information licensed to such third parties. AELYN will not share your information after AELYN has received your notification that you are opting out. If you wish to opt-out, send an e-mail to: team@beaelyn.com.

Effective January 1, 2020, if you reside in California you have the following rights:

• You have the right to opt-out of AELYN’s sale of your Personal Information.
• You have the right to request the deletion of your Personal Information.
• You have the right to request us to disclose to you the following, no more than twice in a 12-month period:

• Categories of Personal Information collected about you during the preceding 12 months.
• Categories of sources from which AELYN collected the Personal Information during the preceding 12 months.
• Business or commercial purpose(s) for collecting or selling your Personal Information during the preceding 12 months.
• Categories of third parties with whom we share the Personal Information during the preceding 12 months.
• Specific pieces of Personal Information we collected about you during the preceding 12 months.
• Categories of Personal Information we have sold and categories of third parties to whom the information was sold to during the preceding 12 months.
• Categories of Personal Information we disclosed about you for a business purpose during the preceding 12 months.

AELYN will not discriminate against you because you exercised your rights under this section.

For purposes of exercising your rights above, please note the following regarding how AELYN collects and use your Personal Information as described in this Notice:

AELYN collects the following categories of personal information: Identifiers; payment information; commercial information; internet of other electronic network activity information; geolocation data; audio, electronic or visual information.

AELYN discloses the following categories of personal information for a business purpose: Identifiers; payment information; commercial information; device information; and demographic information.

AELYN sells the following categories of personal information: Identifiers; payment information; event information; demographic information; device information; location information; commercial information; internet or other network activity information.

7. What kinds of security procedures are in place to protect against the loss, misuse or alteration of your information? The Site has security measures equal to or better than those reasonably expected in the industry, such as firewalls, in place to protect against the loss, misuse and alteration of your Personal Information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, AELYN takes reasonable precautions to prevent such unfortunate occurrences.

You are ultimately responsible for the security of your AELYN login credentials. You may not share your AELYN login credentials with colleagues or friends. You should log out of your browser at the end of each computer session to ensure that others cannot access your Personal Information and correspondence, especially if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.

8. Tracking Technologies. AELYN may employ the following tracking technologies on its Applications (as defined in the Terms and this Policy):
9. Cookies: “Cookies” give users a special ID, which are small text files that are stored in the memory of a user’s computer, mobile, e-reader, tablet or other device used to access the AELYN Applications (“Device”). AELYN employs cookies to recognize you and your access privileges for certain locations on the Devices as well as to track site usage. Subscribers who do not accept cookies from the Devices cannot access many areas of the Devices. We use both “session ID cookies” and “persistent cookies.” Session ID cookies are used to store information while a user is logged into the Devices and expire when the user closes his/her browser. Persistent cookies are used to make tasks like logging into the Devices easier for returning users by remembering a user’s login information. Persistent cookies stay on a user’s hard drive from one session to the next. 
10. Web Beacons: Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Devices, to monitor how users navigate the Devices, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.
11. Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Devices, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Devices, and is deactivated or deleted thereafter.
12. HTML5: We may use HTML5 in the Devices, including without limitation in ADLEAKS mobile websites and certain mobile applications for the iPhone or iPad (and any other Apple iOS device). HTML5 has browser web storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies are not stored in a browser “cookies” file and, like Flash cookies, can be used to track users across websites. We are currently unaware of a way for a user to disable local storage while simultaneously leaving cookies enabled.
13. E-tags/cache browsers/web logs: Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) and Device identification in order to improve security, analyze trends and administer the Devices. We may track your movement within the Devices, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the Internet address from which you linked to our Devices, the operating system of your computer, the unique IP address of the computer or Device identification from the Device that you used to access our Devices and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our Devices, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather information. We may also use individual information we collect through web logs to send you targeted offers and other communications.

PART II – AELYN PRIVACY POLICY FOR INFORMATION COLLECTED OTHER THAN THROUGH THE SITE

The same rules set forth in Part I above for the Site will be applied to such Personal Information you submit through channels other than the Site (including without limitation your opt-out rights in Part I, Section 6 above), except as follows:

1. The “cookies” and other tracking devices used by the Site and described in Part I above do not apply to Personal Information gathered through channels other than the Site.
2. Hardcopy Personal Information provided to AELYN which is not converted to electronic media or hosted by AELYN will be subject to different security procedures than electronically stored Personal Information. AELYN has security measures equal to or better than those reasonably expected in the industry, in place to protect against the loss, misuse and alteration of your hardcopy Personal Information under Aelyn’s control.
3. When AELYN collects Personal Information through channels other than the Site it may in some instances apply a different privacy policy to such information; but where it does so it shall conspicuously disclose to you at the time of collection what policy will apply to such information. For example, AELYN may collect survey information through a survey where AELYN’s use of any Personal Information from that survey is more limited than the general policy would otherwise allow; in such a case AELYN will disclose the stricter policy governing that survey information at the time such Personal Information is collected from the survey respondent.

QUESTIONS

If you have any questions or complaints regarding this Privacy Policy or the Site, please contact AELYN at team@beaelyn.com.