Our Terms and Policies
- Acceptable Use Policy
- Legal Requests
- Return and Refund Policy
- Cookies Policy
- Copyright and Trademark Policy
- data protection policy
- Register of systems
Last updated May 24, 2018
AGREEMENT TO TERMS
The information provided on these Sites is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject us to any registration requirement within such jurisdiction or country.
Accordingly, those persons who choose to access these Sites from other locations do so on their own initiative and are solely responsible for compliance with local laws, if and to the extent local laws are applicable.
Any use or access by anyone under the age of 13 is prohibited, and certain product and/or course content may have additional requirements and/or restrictions.
INTELLECTUAL PROPERTY RIGHTS
Unless otherwise indicated, these Sites are our proprietary property and all source code, databases, functionality, software, website designs, audio, video, text, photographs, and graphics on these Sites (collectively, the “Content”) and the trademarks, service marks, and logos contained therein (the “Marks”) are owned or controlled by us or licensed to us, and are protected by copyright and trademark laws and various other intellectual property rights and unfair competition laws of the United States, foreign jurisdictions, and international conventions.
Provided that you are eligible to use these Sites, you are granted a limited license to access and use these Sites and to download or print a copy of any portion of the Content to which you have properly gained access solely for your personal, non-commercial use. We reserve all rights not expressly granted to you in and to these Sites, the Content and the Marks.
By using these Sites, you represent and warrant that:
(1) all registration information you submit will be true, accurate, current, and complete;
(2) you will maintain the accuracy of such information and promptly update such registration information as necessary;
(4) you are not a minor in the jurisdiction in which you reside
(5) you will not access these Sites through automated or non-human means, whether through a bot, script or otherwise;
(6) you will not use these Sites for any illegal or unauthorized purpose;
(7) your use of these Sites will not violate any applicable law or regulation.
If you provide any information that is untrue, inaccurate, not current, or incomplete, we have the right to suspend or terminate your account and refuse any and all current or future use of these Sites (or any portion thereof).
You may be required to register with these Sites. You agree to keep your password confidential and will be responsible for all use of your account and password. We reserve the right to remove, reclaim, or change a username you select if we determine, in our sole discretion, that such username is inappropriate, obscene, or otherwise objectionable.
Please review our Refund Policy (refer to the TAB above) posted on this site prior to making any purchases.
You may not access or use these Sites for any purpose other than that for which we make these Sites available. These Sites may not be used in connection with any commercial endeavors except those that are specifically endorsed or approved by us.
As a user of these Sites, you agree not to:
- systematically retrieve data or other content from these Sites to create or compile, directly or indirectly, a collection, compilation, database, or directory without written permission from us.
- make any unauthorized use of these Sites, including collecting usernames and/or email addresses of users by electronic or other means for the purpose of sending unsolicited email, or creating user accounts by automated means or under false pretenses.
- use a buying agent or purchasing agent to make purchases on these Sites.
- use these Sites to advertise or offer to sell goods and services.
- circumvent, disable, or otherwise interfere with security-related features of these Sites, including features that prevent or restrict the use or copying of any Content or enforce limitations on the use of these Sites and/or the Content contained therein.
- engage in unauthorized framing of or linking to these Sites.
- trick, defraud, or mislead us and other users, especially in any attempt to learn sensitive account information such as user passwords.
- make improper use of our support services or submit false reports of abuse or misconduct.
- engage in any automated use of the system, such as using scripts to send comments or messages, or using any data mining, robots, or similar data gathering and extraction tools.
- interfere with, disrupt, or create an undue burden on these Sites or the networks or services connected to these Sites.
- attempt to impersonate another user or person or use the username of another user.
- sell or otherwise transfer your profile.
- use any information obtained from these Sites in order to harass, abuse, or harm another person.
- use these Sites as part of any effort to compete with us or otherwise use these Sites and/or the Content for any revenue-generating endeavor or commercial enterprise.
- decipher, decompile, disassemble, or reverse engineer any of the software comprising or in any way making up a part of these Sites.
- attempt to bypass any measures of these Sites designed to prevent or restrict access to these Sites, or any portion of these Sites.
- harass, annoy, intimidate, or threaten any of our employees or agents engaged in providing any portion of these Sites to you.
- delete the copyright or other proprietary rights notice from any Content.
- upload or transmit (or attempt to upload or to transmit) viruses, Trojan horses, or other material, including excessive use of capital letters and spamming (continuous posting of repetitive text), that interferes with any party’s uninterrupted use and enjoyment of these Sites or modifies, impairs, disrupts, alters, or interferes with the use, features, functions, operation, or maintenance of these Sites.
- upload or transmit (or attempt to upload or to transmit) any material that acts as a passive or active information collection or transmission mechanism, including without limitation, clear graphics interchange formats (“gifs”), 1×1 pixels, web bugs, cookies, or other similar devices (sometimes referred to as “spyware” or “passive collection mechanisms” or “pcms”).
- except as may be the result of standard search engine or Internet browser usage, use, launch, develop, or distribute any automated system, including without limitation, any spider, robot, cheat utility, scraper, or offline reader that accesses these Sites, or using or launching any unauthorized script or other software.
- disparage, tarnish, or otherwise harm, in our opinion, us and/or these Sites.
- use these Sites in a manner inconsistent with any applicable laws or regulations.
USER GENERATED CONTRIBUTIONS
These Sites may invite you to chat, contribute to, or participate in blogs, message boards, online forums, and other functionality, and may provide you with the opportunity to create, submit, post, display, transmit, perform, publish, distribute, or broadcast content and materials to us or on these Sites, including but not limited to text, writings, video, audio, photographs, graphics, comments, suggestions, or personal information or other material (collectively, "Contributions").
Contributions may be viewable by other users of these Sites and through third-party websites. As such, any Contributions you transmit may be treated as non-confidential and non-proprietary. When you create or make available any Contributions, you thereby represent and warrant that:
- the creation, distribution, transmission, public display, or performance, and the accessing, downloading, or copying of your Contributions do not and will not infringe the proprietary rights, including but not limited to the copyright, patent, trademark, trade secret, or moral rights of any third party.
- your Contributions are not false, inaccurate, or misleading.
- your Contributions are not unsolicited or unauthorized advertising, promotional materials, pyramid schemes, chain letters, spam, mass mailings, or other forms of solicitation.
- your Contributions are not obscene, lewd, lascivious, filthy, violent, harassing, libelous, slanderous, or otherwise objectionable (as determined by us).
- your Contributions do not ridicule, mock, disparage, intimidate, or abuse anyone.
- your Contributions do not advocate the violent overthrow of any government or incite, encourage, or threaten physical harm against another.
- your Contributions do not violate any applicable law, regulation, or rule.
- your Contributions do not violate the privacy or publicity rights of any third party.
- your Contributions do not contain any material that solicits personal information from anyone under the age of 18 or exploits people under the age of 18 in a sexual or violent manner.
- your Contributions do not violate any federal or state law concerning child pornography, or otherwise intended to protect the health or well-being of minors;
- your Contributions do not include any offensive comments that are connected to race, national origin, gender, sexual preference, or physical handicap.
We do not assert any ownership over your Contributions. You retain full ownership of all of your Contributions and any intellectual property rights or other proprietary rights associated with your Contributions. We are not liable for any statements or representations in your Contributions provided by you in any area on these Sites.
You are solely responsible for your Contributions to these Sites and you expressly agree to exonerate us from any and all responsibility and to refrain from any legal action against us regarding your Contributions.
We have the right, in our sole and absolute discretion, (1) to edit, redact, or otherwise change any Contributions; (2) to re-categorize any Contributions to place them in more appropriate locations on these Sites; and (3) to pre-screen or delete any Contributions at any time and for any reason, without notice. We have no obligation to monitor your Contributions.
You acknowledge and agree that any questions, comments, suggestions, ideas, feedback, or other information regarding these Sites ("Submissions") provided by you to us are non-confidential and shall become our sole property. We shall own exclusive rights, including all intellectual property rights, and shall be entitled to the unrestricted use and dissemination of these Submissions for any lawful purpose, commercial or otherwise, without acknowledgment or compensation to you.
You hereby waive all moral rights to any such Submissions, and you hereby warrant that any such Submissions are original with you or that you have the right to submit such Submissions. You agree there shall be no recourse against us for any alleged or actual infringement or misappropriation of any proprietary right in your Submissions.
THIRD-PARTY WEBSITES AND CONTENT
These Sites may contain (or you may be sent via these Sites) links to other websites ("Third-Party Websites") as well as articles, photographs, text, graphics, pictures, designs, music, sound, video, information, applications, software, and other content or items belonging to or originating from third parties ("Third-Party Content").
Such Third-Party Websites and Third-Party Content are not investigated, monitored, or checked for accuracy, appropriateness, or completeness by us, and we are not responsible for any Third-Party Websites accessed through these Sites or any Third-Party Content posted on, available through, or installed from these Sites, including the content, accuracy, offensiveness, opinions, reliability, privacy practices, or other policies of or contained in the Third-Party Websites or the Third-Party Content.
You should review the applicable terms and policies, including privacy and data gathering practices, of any website to which you navigate from these Sites or relating to any applications you use or install from these Sites. Any purchases you make through Third-Party Websites will be through other websites and from other companies, and we take no responsibility whatsoever in relation to such purchases which are exclusively between you and the applicable third party.
You agree and acknowledge that we do not endorse the products or services offered on Third-Party Websites and you shall hold us harmless from any harm caused by your purchase of such products or services. Additionally, you shall hold us harmless from any losses sustained by you or harm caused to you relating to or resulting in any way from any Third-Party Content or any contact with Third-Party Websites.
We reserve the right, but not the obligation, to:
(3) in our sole discretion and without limitation, refuse, restrict access to, limit the availability of, or disable (to the extent technologically feasible) any of your Contributions or any portion thereof;
(4) in our sole discretion and without limitation, notice, or liability, to remove from these Sites or otherwise disable all files and content that are excessive in size or are in any way burdensome to our systems;
(5) otherwise manage these Sites in a manner designed to protect our rights and property and to facilitate the proper functioning of these Sites.
DIGITAL MILLENNIUM COPYRIGHT ACT (DMCA) NOTICE AND POLICY
We respect the intellectual property rights of others. If you believe that any material available on or through these Sites infringes upon any copyright you own or control, please immediately notify our Designated Copyright Agent using the contact information provided below (a “Notification”).
A copy of your Notification will be sent to the person who posted or stored the material addressed in the Notification. Please be advised that pursuant to federal law you may be held liable for damages if you make material misrepresentations in a Notification. Thus, if you are not sure that material located on or linked to by these Sites infringes your copyright, you should consider first contacting an attorney.
All Notifications should meet the requirements of DMCA 17 U.S.C. § 512(c)(3) and include the following information:
(1) A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;
(2) identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works on these Sites are covered by the Notification, a representative list of such works on these Sites;
(3) identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material;
(4) information reasonably sufficient to permit us to contact the complaining party, such as an address, telephone number, and, if available, an email address at which the complaining party may be contacted;
(5) a statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law;
(6) a statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed upon.
If you believe your own copyrighted material has been removed from these Sites as a result of a mistake or misidentification, you may submit a written counter notification to us using the contact information provided below (a “Counter Notification”).
To be an effective Counter Notification under the DMCA, your Counter Notification must include substantially the following:
(1) identification of the material that has been removed or disabled and the location at which the material appeared before it was removed or disabled;
(2) a statement that you consent to the jurisdiction of the Federal District Court in which your address is located, or if your address is outside the United States, for any judicial district in which we are located;
(3) a statement that you will accept service of process from the party that filed the Notification or the party's agent;
(4) your name, address, and telephone number;
(5) a statement under penalty of perjury that you have a good faith belief that the material in question was removed or disabled as a result of a mistake or misidentification of the material to be removed or disabled;
(6) your physical or electronic signature.
If you send us a valid, written Counter Notification meeting the requirements described above, we will restore your removed or disabled material, unless we first receive notice from the party filing the Notification informing us that such party has filed a court action to restrain you from engaging in infringing activity related to the material in question.
Please note that if you materially misrepresent that the disabled or removed content was removed by mistake or misidentification, you may be liable for damages, including costs and attorney's fees. Filing a false Counter Notification constitutes perjury.
Designated Copyright Agent
777 E Main Street
Ashland, OR 97520
We respect the intellectual property rights of others. If you believe that any material available on or through these Sites infringes upon any copyright you own or control, please immediately notify us using the contact information provided below (a “Notification”). A copy of your Notification will be sent to the person who posted or stored the material addressed in the Notification.
Please be advised that pursuant to federal law you may be held liable for damages if you make material misrepresentations in a Notification. Thus, if you are not sure that material located on or linked to by these Sites infringes your copyright, you should consider first contacting an attorney.]
TERM AND TERMINATION
If we terminate or suspend your account for any reason, you are prohibited from registering and creating a new account under your name, a fake or borrowed name, or the name of any third party, even if you may be acting on behalf of the third party.
In addition to terminating or suspending your account, we reserve the right to take appropriate legal action, including without limitation pursuing civil, criminal, and injunctive redress.
MODIFICATIONS AND INTERRUPTIONS
We reserve the right to change, modify, or remove the contents of these Sites at any time or for any reason at our sole discretion without notice. However, we have no obligation to update any information on our Sites. We also reserve the right to modify or discontinue all or part of these Sites without notice at any time.
We will not be liable to you or any third party for any modification, price change, suspension, or discontinuance of these Sites.
We cannot guarantee these Sites will be available at all times. We may experience hardware, software, or other problems or need to perform maintenance related to these Sites, resulting in interruptions, delays, or errors. We reserve the right to change, revise, update, suspend, discontinue, or otherwise modify these Sites at any time or for any reason without notice to you.
Any legal action of whatever nature brought by either you or us (collectively, the “Parties” and individually, a “Party”) shall be commenced or prosecuted in the state and federal courts located in Jackson County, Oregon and the Parties hereby consent to, and waive all defenses of lack of personal jurisdiction and forum non conveniens with respect to venue and jurisdiction in such state and federal courts.
If the Parties are unable to resolve a Dispute through informal negotiations, the Dispute (except those Disputes expressly excluded below) will be finally and exclusively resolved by binding arbitration. YOU UNDERSTAND THAT WITHOUT THIS PROVISION, YOU WOULD HAVE THE RIGHT TO SUE IN COURT AND HAVE A JURY TRIAL.
The arbitration shall be commenced and conducted under the Commercial Arbitration Rules of the American Arbitration Association ("AAA") and, where appropriate, the AAA’s Supplementary Procedures for Consumer Related Disputes ("AAA Consumer Rules"), both of which are available at the AAA website www.adr.org.
Your arbitration fees and your share of arbitrator compensation shall be governed by the AAA Consumer Rules and, where appropriate, limited by the AAA Consumer Rules.
The arbitration may be conducted in person, through the submission of documents, by phone, or online. The arbitrator will make a decision in writing, but need not provide a statement of reasons unless requested by either Party. The arbitrator must follow applicable law, and any award may be challenged if the arbitrator fails to do so.
Except where otherwise required by the applicable AAA rules or applicable law, the arbitration will take place in Jackson County, Oregon. Except as otherwise provided herein, the Parties may litigate in court to compel arbitration, stay proceedings pending arbitration, or to confirm, modify, vacate, or enter judgment on the award entered by the arbitrator.
In no event shall any Dispute brought by either Party related in any way to these Sites be commenced more than 2 years after the cause of action arose. If this provision is found to be illegal or unenforceable, then neither Party will elect to arbitrate any Dispute falling within that portion of this provision found to be illegal or unenforceable and such Dispute shall be decided by a court of competent jurisdiction within the courts listed for jurisdiction above, and the Parties agree to submit to the personal jurisdiction of that court.
THESE SITES ARE PROVIDED ON AN AS-IS AND AS-AVAILABLE BASIS. YOU AGREE THAT YOUR USE OF THESE SITES SERVICES WILL BE AT YOUR SOLE RISK. TO THE FULLEST EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, IN CONNECTION WITH THESE SITES AND YOUR USE THEREOF, INCLUDING, WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE MAKE NO WARRANTIES OR REPRESENTATIONS ABOUT THE ACCURACY OR COMPLETENESS OF THESE SITES’ CONTENT OR THE CONTENT OF ANY WEBSITES LINKED TO THESE SITES AND WE WILL ASSUME NO LIABILITY OR RESPONSIBILITY FOR ANY (1) ERRORS, MISTAKES, OR INACCURACIES OF CONTENT AND MATERIALS, (2) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF THE SITE, (3) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION AND/OR FINANCIAL INFORMATION STORED THEREIN, (4) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM THESE SITES, (5) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE WHICH MAY BE TRANSMITTED TO OR THROUGH THESE SITES BY ANY THIRD PARTY, AND/OR (6) ANY ERRORS OR OMISSIONS IN ANY CONTENT AND MATERIALS OR FOR ANY LOSS OR DAMAGE OF ANY KIND INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE VIA THESE SITES. WE DO NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR ANY PRODUCT OR SERVICE ADVERTISED OR OFFERED BY A THIRD PARTY THROUGH THESE SITES, ANY HYPERLINKED WEBSITE, OR ANY WEBSITE OR MOBILE APPLICATION FEATURED IN ANY BANNER OR OTHER ADVERTISING, AND WE WILL NOT BE A PARTY TO OR IN ANY WAY BE RESPONSIBLE FOR MONITORING ANY TRANSACTION BETWEEN YOU AND ANY THIRD-PARTY PROVIDERS OF PRODUCTS OR SERVICES. AS WITH THE PURCHASE OF A PRODUCT OR SERVICE THROUGH ANY MEDIUM OR IN ANY ENVIRONMENT, YOU SHOULD USE YOUR BEST JUDGMENT AND EXERCISE CAUTION WHERE APPROPRIATE.
LIMITATIONS OF LIABILITY
IN NO EVENT WILL WE OR OUR DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, SPECIAL, OR PUNITIVE DAMAGES, INCLUDING LOST PROFIT, LOST REVENUE, LOSS OF DATA, OR OTHER DAMAGES ARISING FROM YOUR USE OF THESE SITES, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
Notwithstanding the foregoing, we reserve the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify us, and you agree to cooperate, at your expense, with our defense of such claims. We will use reasonable efforts to notify you of any such claim, action, or proceeding which is subject to this indemnification upon becoming aware of it.
We will maintain certain data that you transmit to these Sites for the purpose of managing the performance of these Sites, as well as data relating to your use of these Sites. Although we perform regular routine backups of data, you are solely responsible for all data that you transmit or that relates to any activity you have undertaken using these Sites.
You agree that we shall have no liability to you for any loss or corruption of any such data, and you hereby waive any right of action against us arising from any such loss or corruption of such data.
ELECTRONIC COMMUNICATIONS, TRANSACTIONS, AND SIGNATURES
Visiting these Sites, sending us emails, and completing online forms constitute electronic communications. You consent to receive electronic communications, and you agree that all agreements, notices, disclosures, and other communications we provide to you electronically, via email and on these Sites, satisfy any legal requirement that such communication be in writing. YOU HEREBY AGREE TO THE USE OF ELECTRONIC SIGNATURES, CONTRACTS, ORDERS, AND OTHER RECORDS, AND TO ELECTRONIC DELIVERY OF NOTICES, POLICIES, AND RECORDS OF TRANSACTIONS INITIATED OR COMPLETED BY US OR VIA THESE SITES.
You hereby waive any rights or requirements under any statutes, regulations, rules, ordinances, or other laws in any jurisdiction which require an original signature or delivery or retention of non-electronic records, or to payments or the granting of credits by any means other than electronic means.
CALIFORNIA USERS AND RESIDENTS
If any complaint with us is not satisfactorily resolved, you can contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento, California 95834 or by telephone at (800) 952-5210 or (916) 445-1254.
In order to resolve a complaint regarding these Sites or to receive further information regarding use of these Sites, please contact us at firstname.lastname@example.org:
Innersource, Unlimited, LLC
777 E Main Street
Ashland, OR 97520
May 19, 2018
- Update domain names to capture all the Company's primary sites. Update singular Site to plural Sites.
- Updated Contact email to email@example.com.
May 20, 2018
- Change prohibited age from 18 to 13, with potential exclusions for age appropriate courses and products
May 24, 2018
- Under “Prohibited Activities” #7 replaced “;” with “.” at end
- Under “Refunds Policy” the word thsse corrected to these
- Under “Disclaimer” the changed from “These Sites is provided on an as-is and as-available basis." to “These Sites is provided on an as-is and as-available basis."
Acceptable Use Policy
Last Updated May 24, 2018
Innersource's mission is to educate and empower individuals, organizations, and communities to heartfully and mindfully maximize their health and optimal functioning through the tools and concepts of Eden Energy Medicine and Energy Psychology. We believe strongly in preserving free expression for our entire community. We also want to make sure that all of our students and instructors feel safe and comfortable while using our Services. We have drafted these guidelines to ensure that people understand and follow the rules when using our Services.
Although we do not routinely screen or monitor content provided by users, we may remove or edit inappropriate content or activity reported to us or suspend, disable, or terminate a user's access to all or part of the Services.
You are prohibited from using our Services to share content that:
- Contains illegal content or promotes illegal activities with the intent to commit such activities.
- Contains credible threats or organizes acts of real-world violence. We don’t allow content that creates a genuine risk of physical injury or property damage, credibly threatens people or public safety, or organizes or encourages harm.
- Harrasses others. We encourage commentary about people and matters of community interest, but abusive or otherwise inappropriate content directed at private individuals is not allowed.
- Violates intellectual property, privacy, or other rights. Do not share content that you do not have the right to share, claim content that you did not create as your own, or otherwise infringe or misappropriate someone else’s intellectual property or other rights. Always attribute materials used or quoted by you to the original copyright owner.
- Spams others. Do not share irrelevant or inappropriate advertising, promotional, or solicitation content.
- Otherwise violates the Innersource Terms and Conditions (refer to the TAB above). Please note that specific courses may have additional rules and requirements.
You also aren't allowed to:
- Do anything that violates local, state, national or international law or breaches any of your contractual obligations or fiduciary duties.
- Share your password, let anyone access your account, or do anything that might put your account at risk.
- Attempt to access any other user's account.
- Reproduce, transfer, sell, resell, or otherwise misuse any content from our Services, unless specifically authorized to do so.
- Access, tamper with, or use non-public areas of our systems, unless specifically authorized to do so.
May 24, 2018
- Removed reference to EEMCentral.com in first paragraph, being handled through separate policy.
- Added Eden to Energy Medicine in first paragraph
Last Updated May 24, 2018
Your privacy is critically important to us. At Innersource, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
Who We Are and What This Policy Covers
We are the home of Donna Eden's Energy Medicine, David Feinstein's Energy Psychology Interactive, and their other programs for living more consciously and more joyfully, the Conscious Living Series. Our mission is to educate and empower individuals, organizations, and communities to heartfully and mindfully maximize their health and optimal functioning through the tools and concepts of Energy Medicine and Energy Psychology.
- Our websites (including EdenEnergyMedicine.com, DonnaEden.com, LearnEnergyMedicine.com, Innersource.net, and Innersource.CustomerHub.net (“Eden Energy Online”);
- Our mobile application for Eden Energy Medicine Central in license with Matrix LMS (includes support for Android and iOS);
- Our other products and services that are available on or through EdenEnergyMedicine.com and our student registration site (Regfox.com) in partnership with Webconnex.
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Creative Commons Sharealike License
Information We Collect
We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.
We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a EdenEnergyMedicine.com Shopping cart account to provide a username and email address–and that’s it. You may provide us with more information–like your name–but we don’t require that information to create a EdenEnergyMedicine.com account.
- Transaction and Billing Information: If you buy something from us–a product from the EdenEnergyMedicine.com store, register for a live course, or online only course through Eden Energy Online, for example–you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
- Affiliate Information: If you offer our ecommerce Services to sell our products or services to others through our site, you have the option to create a EdenEnergyMedicine.com/affiliate account or log into an existing account. As an affiliate, you will typically provide us with information about your financial account for commission payments, such as the email address for your PayPal account and your TaxID/SSN for accounting purposes.
- Content and Communications With Us: Depending on the Services you use, you may also provide us with information about you through feedback surveys, testimonials, photos, videos, emails and/or written letters. For example, you may write to us for clarity on a question regarding your education, we will have that information, and so will anyone with access to the Internet if you choose to post the feedback on our website or community forums such as Facebook. This might be obvious to you…but it’s not to everyone!
Information We Collect Automatically
We also collect some information automatically:
- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services–for example, when you visit our website on EdenEnergyMedicine.com. We do this for marketing and security reasons. We do not track or store the full IP Address, only the first six digits to track originating country/region, nor do we correlate or store specific IP addresses to a user account or with any unique identifier that will be correlate with a specific user in our system.
- Usage Information: We collect information about your usage of our Services. For example, we collect information about the actions that users perform on Eden Energy Online and EEM Central–in other words, who did what, when and to what thing on a site (e.g., [Eden Energy Online user] logged in at [time/date]). As another example, our EEM Central Online Education Platform tracks information like the last time you entered a course, where you are at in completing the course, and assignments completed or in progress. We also collect information about what happens when you use our Services (e.g., page views, support document searches on EdenEnergyMedicine.com and other parts of our Services). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
- Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
- Stored Information: We may access information stored on your mobile device via our mobile app. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access a file on your mobile device, our Services may access the files stored on your device when you upload to complete an assignment on EEM Central.
How And Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
- To provide our Services–for example, to offer products and courses, provide access to our online services (e.g. Eden Energy Online and EEM Central), or charge you for any of our paid Services;
- To further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to create and manage their websites more efficiently;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyze how many individuals purchased a product after receiving a marketing message or the courses that have the highest usage history over a certain length of time;
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Innersource and others, which may result in us declining a transaction or the use of our Services;
- To communicate with you, for example through an email, about offers and promotions offered by Innersource and others we think will be of interest to you, solicit your feedback, or keep you up to date on Innersource and our products; and
- To personalize your experience using our Services, provide content recommendations (for example, through our course feedback surveys), target our marketing messages to groups of our users (for example, those who have taken a particular course with us or have been our user for a certain length of time), and serve relevant advertisements.
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account–for example, in order to enable access to our website on your device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
How We Share Information
We do not sell our users’ private personal information.
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), and companies that make products available on our websites (such as the extension for our EdenEnergyMedicine.com), who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them. Our vendors and your personal data we store with them are listed here.
- Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request. For more information on how we respond to requests for information about EdenEnergyMedicine.com users, please see our Legal Request (refer to the TAB above).
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Innersource, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties such as a hotel when you are registering for an event and we are coordinate accommodations.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns with partners.
- Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.
Information Shared Publicly
Information that you choose to make public is–you guessed it–disclosed publicly.
That means, of course, that information like your public profile, posts, other content that you make public on our website, and your “Likes” and comments, are all available to others.
For example, a comment or post you might make on a EdenEnergyMedicine.com blog, along with other profile information you may make available within your posts.
Please keep all of this in mind when deciding what you would like to share.
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it–which are described in the section above on How and Why We Use Information–and we are not legally required to continue to keep it.
For example, we keep the web server logs that record information about a visitor to one of Innersource’s websites, such as the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Innersource’s websites and investigate issues if something goes wrong on one of our websites.
As another example, we will retain information up to 30 days after a live event in the event there is customer service or support question related to who attended, arrival date and departure date.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
You have several choices available when it comes to information about you:
- Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services–for example, automatic notifications and updates–may not be accessible.
- Limit Access to Information On Your Mobile Device: Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features (like adding a location to a photograph, for example).
- Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
- Set Your Browser to Reject Cookies: At this time, Innersource does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Innersource’s websites, with the drawback that certain features of Innersource’s websites may not function properly without the aid of cookies.
- Close Your Account: While we’d be very sad to see you go, if you no longer want to be part of our community, you can close your any and/or all of your accounts with us.. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, tax obligations, or reasonably needed for our legitimate business interests.
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.
EU individuals also have the right to make a complaint to a government supervisory authority.
How to Reach Us
Other Things You Should Know (Keep Reading!)
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
May 18, 2018 - Updated Information Shared Publicly to remove "and we hope you get a lot of views!" and Updated Who We are and What Our Policy Covers - 2nd bullet point from "in partnership with Matrix LMS" to "in license with Matrix LMS"
May 24, 2018
- Removed 🙁 🙁 🙁 🙁
- Removed EEMCentral example and replaced with "For example, a comment or post you might make on a EdenEnergyMedicine.com blog, along with other profile information you may make available within your posts."
- Removed from "Who We Are and What This Policy Covers" EEMCentral.com and EEMTribe.com since will be handled through separate policies.
Last Updated May 20, 2018
What Information Do We Have?
Our websites ("EdenEnergyMedicine.com, DonnaEden.com, LearnEnergyMedicine.com, Innersource.CustomerHub.Net ("Eden Energy Online"), and Innersource.net) have certain information from users. The following is a summary of the information that we may collect and store.
1. Basic account information, such as:
- Email address
- Phone number
- Order and purchase information
- PCI compliant credit card data for future purchase (optional per customer choice), accounting and tax purposes
2. Transaction and/or billing information
- We will generally retain the above information until changed or removed by the user (if it’s possible to do so). We also collect log data, which may include a user’s IP address, browser type, operating system. We keep this information for up to 30 days as a matter of course.
3. Live Event Registration Data:
- Email address
- Phone number
- Emergency Contact Phone Number
- Emergency Contact Phone Number
- Personal preferences regarding accommodations and meals
We may retain the above information for reporting purposes up to 30 days after the event completes.
More Information on Data Release and Retention
Before revealing any of this information to a party that is not the owner of the account, we require a validly issued subpoena, warrant, or court order that specifically requests it unless we have a good faith belief that there is an emergency involving death or serious physical injury. We do not voluntarily provide governments with access to data about users (private or public) for law enforcement, intelligence gathering, or other surveillance purposes. More information on our requirements for releasing private user information can be found below.
If you wish to stop using our websites, you may request to have your account removed from our systems by contacting us at firstname.lastname@example.org.
May 19, 2018 - Update email address to email@example.com. Updated from EEMCentral.com only to our websites.
May 20- 2018
- Removed EEMCentral.com and EEMTribe.com. They will be handled under separate policies
- Added to Basic Account Information - "Order and purchase information"
- Added to Basic Account Information - "PCI compliant credit card data for future purchase (optional per customer choice), accounting and tax purposes"
Course Refund Policy
Last Update May 24, 2018
Withdrawals 45 or more days before the start of class will receive a full refund for tuition (including Review and Post Class) - minus an $80 administrative fee.
Withdrawals must be emailed to firstname.lastname@example.org and will be promptly acknowledged once received.
If you do not notify us at all of your withdrawal (i.e. if you do not attend a class for which you registered), you will not receive any refund and you will also be responsible for all hotel charges that have been incurred in your name for that class.
In the case of emergencies (death or injury) or catastrophic (natural or accidental) events, you may contact Innersource to discuss your situation. In these instances, decisions will be made on a case–by–case basis.
YEAR 2 ONLY: If you choose to rejoin the program the following year at the next class for which you are eligible, your $300 non-refundable deposit will be carried over and applied to that year's Class 8. If you do not rejoin the program the following year after your cancellation, your $300 non-refundable deposit is forfeited.
* If you have paid for a class and then withdraw less than 45 days before the start of the class, you will receive a 50% refund for tuition (including Review and Post Class) - minus the cost of your entire hotel reservation that Innersource made for you if you made a Private hotel room reservation.
Innersource has to guarantee room reservations 45 days prior to the event and if you cancel, Innersource will still be charged for your hotel reservation and must then pass on that expense to you.
You may return new, unopened items sold and fulfilled by Innersource within 30 days of delivery for a full refund minus shipping fees. Refunds will be applied to the credit card used to make the purchase. If you paid with a check or cash, your refund will remain a credit on your account. NOTE: You are responsible for the return shipping costs.
Items should be returned in their original packaging. Opened items, items showing use or wear and items otherwise not resalable will receive a reduced refund reflecting the decreased value.
Holiday Returns Policy
We understand that many customers order holiday gifts early, so we've extended our returns period for the holiday shopping season. Items shipped between November 1 and December 31 may be returned or exchanged through January 31, subject to the returns guidelines listed above.
Details of our return policy rules and exceptions:
Items that are Not Returnable
Innersource does not accept returns for items purchased from sellers other than Innersource.
Partial Refunds will be issued for the following items:
- Most items that are returned more than 30 days after delivery.
- Any item that has obvious signs of use or damage
- Any CD, DVD, software, or cassette tape, that has been opened/taken out of its plastic wrap. (If you discover that the item is defective after the package is opened, a full refund or replacement will still be granted.)
If you would like to exchange a new, unopened item for a different product, email our Order Fulfillment Team at email@example.com or call 541-488-7662 to place a new order (you will be refunded your original purchase price once we receive the item).
(Please note that it takes 3 to 5 business days to process returns once they arrive at our order fulfillment center)
May 24, 2018 - Added General Returns policy section.
Last updated May 24, 2018
TYPES OF COOKIES
The following types of cookies may be used when you visit these Sites:
Analytics cookies monitor how users reached these Sites, and how they interact with and move around once on these Sites. These cookies let us know what features on these Sites are working the best and what features on these Sites can be improved.
Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won't work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.
Personalization cookies are used to recognize repeat visitors to these Sites. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit these Sites. We also track for example whether or not you already requested to be added to our newsletter, so the next time you visit our site we do not display to you our request to be added to the newsletter.
Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.
Site Management Cookies
Site management cookies are used to maintain your identity or session on each Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.
Third-party cookies may be place on your computer when you visit these Sites by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser. For example, we embed videos from YouTube and Video which demonstrate our work and each of those website providers use their own tracking cookies.
CONTROL OF COOKIES
Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of these Sites.
For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies, or visit the following links:
In addition, you may opt-out of some third-party cookies through the Network Advertising Initiative’s Opt-Out Tool.
OTHER TRACKING TECHNOLOGIES
In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on these Sites to help customize these Sites and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.
Innersource, Unlimited, LLC
777 E Main Street
Ashland, OR 97520
May 19, 2018 - Update domain names to capture all the Company's primary sites. Update singular Site to plural Sites.
May 24, 2018 -
- Removed EEMCentral.com and EEMTribe.com. These sites will be handled under own Cookies Policy.
- Added to Personalization Cookies section - "We also track for example whether or not you already requested to be added to our newsletter, so the next time you visit our site we do not display to you our request to be added to the newsletter."
- Added to Third Party Cookies section "For example, we embed videos from YouTube and Video which demonstrate our work and each of those website providers use their own tracking cookies."
- Removed Advertising Cookies Section - we currently do not run ads on our websites.
Copyright and Trademark Policy
Last Updated May 18, 2018
Copyright © Innersource, Unlimited, LLC 2018 All Rights Reserved
Innersource respects the intellectual property rights of our business partners, instructors, and other third parties and expects our users to do the same when using the Services. We reserve the right to suspend, disable, or terminate the accounts of users who repeatedly infringe or are repeatedly charged with infringing the copyrights, trademarks, or other intellectual property rights of others.
All files and information contained in this Website or Blog are copyright by Innersource, Unlimited, LLC, and may not be duplicated, copied, modified or adapted, in any way without our written permission. Our Website or Blog may contain our service marks or trademarks as well as those of our affiliates or other companies, in the form of words, graphics, and logos.
Your use of our Website, Blog or Services does not constitute any right or license for you to use our service marks or trademarks, without the prior written permission of Innersource, Unlimited, LLC.
Our Content, as found within our Website, Blog and Services, is protected under United States and foreign copyrights. The copying, redistribution, use or publication by you of any such Content, is strictly prohibited. Your use of our Website and Services does not grant you any ownership rights to our Content.
The Digital Millennium Copyright Act of 1998 (the "DMCA") provides recourse for copyright owners who believe that material appearing on the Internet infringes their rights under U.S. copyright law. If you would like to read the DMCA, please visit the U.S. Copyright Office website at http://www.copyright.gov/legislation/dmca.pdf.
Innersource also respects the trademark rights of others. Accounts with any other content that misleads others or violates another's trademark may be updated, suspended, disabled, or terminated by Innersource in its sole discretion. If you are concerned that someone may be using your trademark in an infringing way on our Services, please email us at privacy@Innersource.net and we will review your complaint. If we deem appropriate, we may remove the offending content, warn the individual who posted the content, and/or temporarily or permanently suspend or disable the individual’s account.
May 19, 2018 - Updated email address to firstname.lastname@example.org
Data Protection Policy
Innersource, Unlimited, LLC
May 18, 2018
Innersource, Unlimited, LLC
means the General Data Protection Regulation.
Jeffrey McDonnell COO/DPO Innersource
contact at email@example.com
Register of Systems
means a register of all systems or contexts in which personal data is processed by the Company.
1. Data protection principles
The Company is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
- This policy applies to all personal data processed by the Company.
- The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- The Company shall register with the Information Commissioner’s Office as an organization that processes personal data.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals shall have the right to ask what information the Company holds about them and why, how to gain access to the information, be informed on how to keep it up to date, and to be informed on how the Company is meeting its data protection obligations.
- Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner.
- The Company at its discretion may charge individuals up to $20 USD per request and will provide all relevant data within 20 business days. The Company will always verify the identity of anyone making a personal data request before handing over any information.
- In certain circumstances, personal data may be requested to be disclosed to law enforcement agencies without the consent of the data subject. For more information regarding personal data request from law enforcement agencies, please see the Company’s Legal Release policy.
4. Lawful purposes
- All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- The Company shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.
5. Data security and minimisation
- The Company shall ensure that all employees keep all data secure, by taking sensible precautions and following the following guidelines:
- Strong passwords must be used, and they should not be shared for non-system administrative functions. In the event that a system administrative function requires a single user account and password, such as a root password on a web server, the account and password will be strictly controlled by a restricted set of administrators, no more than necessary to adequately support the business needs.
- Personal data not be disclosed to unauthorized people, either within the Company or externally.
- The Company should avoid saving personal data directly on laptops or other mobile devices like tablets or smart phones. If there is a need to transfer personal data to a laptop or mobile device for a very specific business need (e.g. exchanging hotel registration information between the event and hotel staff, providing user name tags and rooming lists etc.), the user will be notified and required to provide explicit consent to the transfer of data on their behalf, as well as the data will be immediately removed from the computing device by the event staff once the data is no longer required to support the business transactions.
- All servers and computers containing data should be protected by approved security software and a firewall.
- Personal data must be encrypted before being transferred electronically.
- The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The Company will provide training to all employees to help them understand their responsibilities in handling data.
- The Company shall ensure that only people able to access data covered by this policy should be those who need it for their work.
- The Company shall ensure that data is not shared informally. When access to confidential information is required, employees will follow strict processes in validating consent from the customer.
- The Company shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
- Data will be held in as few places as necessary. Staff should not create unnecessary additional data sets.
- Staff should take every opportunity to ensure that data is updated. For example, by confirming a customer’s details when they call.
- The Company will make it easy for customers to update the information held about them. For instance, via the company website.
- Once inaccuracies are discovered, data should be updated. For instance, if a customer can no longer be reached on the telephone number stored in the database, it should be removed.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
- In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
END OF POLICY
May 19, 2018 - Updated contact person to Jeffrey McDonnell and contact email to firstname.lastname@example.org
May 24, 2018 - Updated Section 6 (f) to "Once inaccuracies are discovered, data should be updated. For instance, if a customer can no longer be reached on the telephone number stored in the database, it should be removed."
Register of Systems
*Web Page is currently in development and will be complete by May 25, 2018
Personal Data Stored
Customer Hub (EEM Online)
Phone Number (Optional)
Matrix LMS (EEM Central)
Phone Number (Optional)
Address (Optional, unless made purchase from store)
Phone Number (Optional)
Phone Number (Optional)
Saved Credit Cards
Phone Number (Optional)
Data Repository for Eden Energy Medicine (DREEM)
Wordfence (WordPress security plugin)
Freshdesk (Being Implemented)
Customer Service History
No customer data, for employee project management use only at this time