Privacy Policy
LAST UPDATED March 28, 2023
This is our Privacy Policy. Please read carefully before using this website.
Introduction
WHAT INFORMATION IS COLLECTED ON THE SITE
USE AND DISCLOSURE OF YOUR INFORMATION COLLECTED ON THE SITE
MODIFICATIONS AND CHANGES TO YOUR INFORMATION
CHOICE AND OPT-OUT
COOKIES AND LOG DATA
DELETION OF PERSONAL DATA
CHILDREN UNDER 16
SECURITY
LINKS TO THIRD PARTY SITES
SOCIAL MEDIA FEATURES
CANADIAN USERS/VISITORS
CALIFORNIA USERS/VISITORS
VIRGINIA USERS/VISITORS
USERS/VISITORS OUTSIDE OF THE U.S.
TESTIMONIALS
PHOTOGRAPHY AND RECORDING
APPLICABLE LAW AND RELEASE
EFFECTIVE DATE/CHANGES TO PRIVACY POLICY
QUESTIONS/CONCERNS
EXHIBIT A
The carolbarash.com website (“Site”) is owned and operated by Carol Barash LLC (“Company,” “we,” “our,” “us”). This privacy policy (“Privacy Policy”) explains how we collect, use, maintain, protect, and disclose information of the Site’s visitors and customers. As used herein, the terms “you”, “your” and “user” refer to all persons and entities accessing the Site on your behalf for any reason.
This policy applies to information we collect:
On this Site.
In email, text, and other electronic messages between you and this Site and/or Company.
From webinars you attend.
It does not apply to information collected by:
Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.
Please read our Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this Site, you are hereby agreeing to be legally bound by our Privacy Policy. If you do not agree with our Privacy Policy, your choice is not to use our Site. This policy may change from time to time (see EFFECTIVE DATE/CHANGES TO PRIVACY POLICY below). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
WHAT INFORMATION IS COLLECTED ON THE SITE
When you register as a user of our Site, we may ask that you provide the following information: e-mail address, screen name, state, zip code, and information about your intended use of site.
When you visit our Site, we collect from you log data as described in the “Cookies and Log Data” section below.
When you purchase products and services on our Site, we will ask you to provide the following personally identifiable information from you: credit card number, credit card expiration date and billing address. We do not store or process this information. This information is used by our third-party payment processors to verify credit card authenticity and process payments for the products and/or services you purchased on our Site. Please note that the third-party processor’s use of your personal information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this privacy policy.
Company customers may email us their questions about our services and our Site at admin@carolbarash.com. We may ask for additional non-personal information to better help us respond to customer service questions. Information you provide, including personally identifying information, when you contact us with a question is used to respond to your question(s) regarding our products and services.
We may also collect other data regarding your use of the Site, such as click-stream data, information about your computer and internet connection (including your IP address, operating system, and browser type), access times, and the referring website addresses (for additional information, see the section titled “Cookies and Log Data” below).
The information we collect on or through our Site may include:
Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Site.
Records and copies of your correspondence (including email addresses), if you contact us.
Details of transactions you carry out through our Site and of the fulfillment of your orders.
Your responses to surveys that we might ask you to complete (see CHOICE AND OPT-OUT below).
Intended use of Site and software.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages through password protection, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
2. USE AND DISCLOSURE OF YOUR INFORMATION COLLECTED ON THE SITE
How We May Use Your Information. We may use the information we collect from and about you on the Site (collectively, “Information”) for any of the following purposes:
to operate the Site;
to fulfill your requests for information, products, services and subscriptions;
to tailor the Site to our customers’ needs;
to contact you and communicate with you about your use of the Site, your user account, courses and services you have enrolled in and registered for;
to send you marketing materials on products and services offered by us or related information from third parties (subject to your opt-in and/or opt-out rights and preferences);
to review Site and product usage and operations and to improve the content and functionality of the Site and our products and services;
to address problems with the Site, our business, products or services;
to notify you about changes to our Site or any products or services we offer or provide though it.
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to protect the security or integrity of the Site and our users and business;
in any other way we may describe when you provide the information; and
For any other purpose with your consent.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: admin@carolbarash.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.
How We May Share Your Information. We may share Information with our subsidiaries and affiliates and third-party service providers with whom we have contracted to provide aspects of the Site or our products and services offered via the Site or who otherwise perform functions on behalf of Company to provide the Site or our products and services, such as hosting providers, credit card processors, and advertisers (subject to your opt-in and/or opt-out rights and preferences).
We reserve the right to disclose Information that we believe is appropriate to cooperate in investigations of fraud or other illegal or inappropriate activity or in response to a subpoena, court order, law, or other legal process, including to respond to any government or regulatory request. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s contact information to victims who request it. If a subpoena seeks information about you, we’ll make reasonable business efforts to contact you before providing information to the party that requests it, but we cannot guarantee that we will be able to do so.
We reserve the right to disclose Information to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant or a guardian appointed for you).
As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition, merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, occurs, the successor company would have access to the information maintained by us, including customer account information, but would continue to be bound by this Privacy Policy, as amended.
3. MODIFICATIONS AND CHANGES TO YOUR INFORMATION
If you are a registered user of our Site, we provide an easy way via your online account profile for you to access, correct, update or remove personal information that has previously been provided to us. You can review your personal information and make any necessary changes at any time by logging in to your user account. If you are unable to edit your personal information by logging into your user account, please contact us for assistance at admin@carolbarash.com. If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users.
4. CHOICE AND OPT-OUT
You may “opt-in” to having your information used for purpose of receiving marketing material from us, our affiliates and/or our third-party advertisers.
If you no longer wish to receive promotional communications from us, our affiliates and/or our third-party advertisers, you may opt-out of receiving them by following the instructions included in each communication or by contacting us at admin@carolbarash.com. Please understand that if you choose not to receive promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
From time to time, we may provide you the opportunity to participate in Company surveys and other information gathering activities to obtain information regarding the use of and possible changes to our products, services and/or the Site and the attractiveness of additional service features or new products or services. Participation in these surveys and activities is completely voluntary and you will usually be provided a choice to participate anonymously. Information obtained from such activities may be used by us to consider enhancements or improvements to the Site and/or our products and services, for future product development or for other purposes pertaining to the Site or Company’s business.
5. COOKIES AND LOG DATA
Unique identifiers such as cookies (which are small text files stored locally on your computer that help store user preferences and may be html files, Flash files or other technology), web beacons, or clear gifs (which are small pieces of code placed on websites used to collect advertising metrics, such as counting page views, promotion views or advertising responses, tags and scripts or similar technologies) (collectively referred to as “Tracking Technologies”) are used by Company and our marketing, analytics, or other service providers to understand Site usage; help customize our content, offerings, or advertisements on the Site; analyze trends; allow users to move between associated websites without logging into each site; and other purposes related to our management and administration of the Site.
We may also use cookies to personalize your experience on the Site (e.g., to recognize you by name when you return to the Site); save your password in password-protected areas; save your online settings; enable you to use shopping carts on the Site; help us offer you products, programs, or services that may be of interest to you; and to deliver relevant advertising. In many Internet browsers, you can choose to delete, disable, turn off, or reject most Tracking Technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature. Additional information on deleting, disabling, rejecting, or turning off Tracking Technologies may be available through your browser’s support feature. Please consult the “Help” section of your browser for more information.
In addition, this Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the Site analyze how users use the Site. The information generated by the cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google. For more information about Google Analytics and how Google uses your information, see here. You may refuse the use of cookies by selecting the appropriate settings on your browser, or by enabling the Do Not Track settings in your browser; however, please note that if you do this you may not be able to use the full functionality of this Site. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Please know that certain areas and features of our Site can only be accessed in conjunction with cookies or similar devices and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content.
Log data collected on web servers supply us with aggregate information about the number of visits to different pages on our Site. We use such aggregate information to improve access to our content based on our visitors’ browsers and operating system types to make our content available to as many users as possible. We do not link the “log data” collected to personality identifying information submitted by users when participating in our activities. This Privacy Policy covers the use of cookies by Company only and does not cover the use of cookies by any advertisers. Some of our third-party providers (e.g., third-party advertisers) may use cookies on our Site. We have no access to or control over these cookies.
By agreeing to this Privacy Policy and using the Site, you are consenting to the use of Tracking Technologies as set forth in this Privacy Policy.
Online Behavioral Advertising: If you do not want third-party advertisers to collect your information for the purpose of sending you interest-based ads, you may opt-out by clicking here. Also, certain third-party advertisers that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You may prevent NAI member companies from collecting preference data about you by following the NAI directions here. Note that this opt-out option does not prevent all ads. You may continue to receive generic ads.
6. DELETION OF PERSONAL DATA
If requested, Company shall, as soon as reasonably practicable and in accordance with applicable law, delete, or return to you, the Personal Data on Company systems, provided that Company may: (a) retain one copy of the Personal Data as necessary to comply with any legal, regulatory, judicial, audit or internal compliance requirements; and (b) defer the deletion of the Personal Data to the extent and for the duration that any Personal Data or copies thereof cannot reasonably and practically be expunged from Company’s systems. For such retention or deferral periods as set out in subparagraphs (a) and (b) of this clause, the provisions of this Privacy Policy shall continue to apply to such Personal Data. Except as may be prohibited by law, Company reserves the right to charge you for any reasonable costs and expenses incurred by Company in deleting or returning the Personal Data pursuant to this clause. If you would like Company to delete your personal data please send your request to admin@carolbarash.com. “Personal Data” means information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, and any other identifier by which you may be contacted online or offline.
7. CHILDREN UNDER 16
This Site is not intended for use by children under 16 years of age and Company does not knowingly collect personal information from children under 16 without the consent of a parent or guardian. If you are under 16, do not use or disclose or provide any personally identifiable information on this Site or through any of its features, register on the Site, make any purchases through the Site, or use any of the interactive or public comment features of this Site. Upon notification that a child under 16 has provided us with personally identifiable information, or if we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete the child’s personally identifiable information from our records. If you believe we might have any information from or about a child under 16, please contact us at admin@carolbarash.com.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see CALIFORNIA USERS/VISITORS below for more information.
8. SECURITY
Company has implemented reasonable technical and organizational measures designed to deter unauthorized access to and use, destruction of, modification of or disclosure of personally identifiable information we collect via the Site. Regardless of the precautions taken by us or by you, no data transmitted over the Internet or any other public network can be guaranteed to be 100% secure. We cannot ensure or warrant the security of any information you transmit to us and you provide all personally identifiable information via the Site at your own risk. You are responsible for maintaining the security of your user profile information, including your password and for any and all activities that occur under your account. Do not share this information with anyone. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on the Site. If you are sharing a computer with anyone, you should always log out before leaving a website or service to protect access to your personally identifiable information from subsequent users. You are responsible for actions that may be taken by anyone using the Site after signing in with your password. We are entitled to rely and act upon instructions received under your username and password.
9. LINKS TO THIRD PARTY SITES
Company may from time to time provide links to other websites that may have their own information collection practices. These other websites are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage visitors to other websites to review the privacy policies and information collection practices of those websites. This Privacy Policy applies solely to the information collected on the Site and does not apply to any information collected by linked websites or the use of any your information by any third party through such linked websites.
10. SOCIAL MEDIA FEATURES
Our Site includes social media features, such as, for example: (1) the Facebook Connect service which gives you the option to post information about your activities on the Site to your Facebook profile page to share with your Facebook network, (2) the Share button which allows you to share a link to our Site with your friends on Twitter, Facebook, LinkedIn and other social media platforms and by email, (3) the Tweet button, which allows you to share a link to our Site with your Twitter network, and (4) the ability to upload video, audio, and photographic material to our Site (collectively, “Social Media Features”). Please be aware that these Social Media Features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the Social Media Feature to properly function. We reserve the right to review and modify any social media, including video, audio, and written posting you submit to our Site. Some Social Media Features may be third-party products and your interactions with those third parties are governed by the privacy policy of the third party providing the applicable Social Media Feature, which may be substantially different from ours.
11. CANADIAN USERS/VISITORS
Canadian citizens, except under circumstances defined by law, are entitled to access their own personal information collected by Company by writing to: admin@carolbarash.com. We may ask you to pay an administrative fee for accessing or copying your personal information, but will inform you of the anticipated charges and confirm that you want us to proceed before processing your request. If you believe that the personal information about you that we have collected is incomplete or inaccurate, we will correct the information upon verification of the omission or error and of the identity of the person requesting the change. If you wish additional information about our personal information management, to access, correct or have us investigate any matters in relation to your personal information, please contact us.
12. CALIFORNIA USERS/VISITORS
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see EXHIBIT A to this Privacy Policy.
California Civil Code Section 1798.83 permits users who are California residents and who have provided with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. In addition, if you are under 18 years old and a California resident, you may submit an application to have any content or material you posted or submitted to our Site using the Social Media Features removed from our Site. Please note that an application to have your material removed does not ensure information you have posted in the past will be completely removed from our systems or our Site or from other websites. If you are a California resident, you may contact us about your rights by writing to admin@carolbarash.com. Do Not Sell My Personal Information: California residents may also opt out of the sale of their personal information by sending us an email stating your request: admin@carolbarash.com.
13. VIRGINIA USERS/VISITORS
Under the Virginia Consumer Data Protection Act (VCDPA), users/visitors of the Site must affirmatively opt-in with consent before we may process sensitive personal data. “Sensitive Data” includes categories of data, including personal data that reveals an individual’s race, ethnic origin, religious beliefs, mental or physical health diagnoses, sexual orientation, citizenship or immigration status; personal data from a known child under 13 years of age; the processing of genetic or biometric data for the purpose of uniquely identifying an individual; and precise geolocation data. Virginia residents must opt-in by clicking on the following option, or elect not to share any Sensitive Data through this Site or with Company:
[insert OPT-IN button]
Under the VCDPA, consumers have the right to know whether a controller is collecting their personal data, to access their collected personal data, to download and remove personal data from a platform in a format that allows the transfer to another, and to correct and delete personal data held on them. Please contact us at admin@carolbarash.com to take any of these actions.
14. USERS/VISITORS OUTSIDE OF THE U.S.
You should be aware that the United States and other countries have not harmonized their privacy regulations. Because Company and its servers are located in the United States and our services are directed towards the United States market, we have written our Privacy Policy pursuant to United States regulations. By using our Site, you agree to the level of privacy protection set out in our Privacy Policy.
15. TESTIMONIALS
We may display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at admin@carolbarash.com
16. PHOTOGRAPHY AND RECORDING
We may record our courses and coaching Sessions for training purposes. Except where prohibited by law, by participating in a Company course or coaching Session, you agree to allow Company to record your participation by audio and video means and to use your likeness, voice, photos, videos, and audio recordings, or portions of any of the foregoing, on our Site and in our training and marketing materials, and on our Site, without notice or compensation to you. If you prefer not to have your photo, video, or audio recordings included, please send your request to admin@carolbarash.com.
17. APPLICABLE LAW AND RELEASE
This Privacy Policy and the relationship between you and Company shall be governed by the laws of the State of New York without regard to its conflict of law provisions. Any dispute arising in connection with this Privacy Policy, the Site, or services provided by Company shall be submitted to the exclusive jurisdiction of the state and federal courts located in New York County, New York, and you expressly consent to, and waive any objection to, the exercise of personal jurisdiction over you by those courts or to the propriety of such venues.
You hereby expressly and perpetually release Company and its owners, employees, managers, officers, directors, parents, subsidiaries, affiliates, members, representatives, agents, successors, and assigns (collectively, “Releasees”), from any and all claims of any kind related to or arising out of the access or use of the Site and/or Company’s services, including but not limited to any injury, loss or damage arising out of or attributable to your participation in Company’s services, whether arising out of the negligence of Company or any other Releasee or otherwise. You expressly and perpetually waive, and covenant not to make or bring, any such claim against Company or any other Releasee, and forever release and discharge Company and all other Releasees from liability under such claims.
18. EFFECTIVE DATE/CHANGES TO PRIVACY POLICY
Each time you use the Site, the current version of this Privacy Policy will apply, however we will provide you with notice via the email address you have provided, in the event we make any material changes to this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes. Users can always refuse to accept the change to our Privacy Policy by terminating their use of the Site and our services offered via the Site. Continuation of such use shall be considered acceptance of the change in the Privacy Policy.
19. QUESTIONS/CONCERNS
If you have any questions, comments, or concerns regarding Company’s Privacy Policy and/or information collection practices, please email us at admin@carolbarash.com.
To see the Terms of Use that apply to the Site, please click here.
You can also contact us by clicking the button below.
20. EXHIBIT A
Company Privacy Notice for California Residents
This Privacy Notice for California Residents supplements the information contained in Company’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
Our Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, Company’s Site has collected the following categories of personal information from its consumers within the last twelve (12) months:
Category
Examples
Collected
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
YES
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES
G. Geolocation data.
Physical location or movements.
NO
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
YES
I. Professional or employment-related information.
Current or past job history or performance evaluations.
YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Company obtains the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Site.
From your school.
Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following business purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Site, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, subscriptions, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To fulfill aspects of partnerships with other educational organizations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Site users is among the assets transferred.
Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
Company may disclose your personal information to a third party for a business purpose [or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights)]. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
Service providers.
Our subsidiaries and affiliates.
Schools, organizations, and other educational partners
Disclosures of Personal Information for a Business Purpose
We disclose your personal information for a business purpose to the following categories of third parties:
Service providers.
Our subsidiaries and affiliates.
Sales of Personal Information
In the preceding twelve (12) months, Company had not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either sending us an email at admin@carolbarash.com.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by sending us an email at admin@carolbarash.com.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by sending us an email at admin@carolbarash.com.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to admin@carolbarash.com.
Changes to Our Privacy Notice
Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which Company collects and uses your information described below and in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at admin@carolbarash.com.