January 10, 2019
We recognize the importance of keeping the information you (“you” or “your”) provide to us
private and secure. This Policy applies, in general, to all Internet sites operated by or on behalf of
us (the “Site”) and related services (the “Services”).
1. User Consent.
By using our Site or providing Personal Information to us, you are consenting to the collection, use
and disclosure of your Personal Information as described in this Policy. If you do not consent to
the collection, use and disclosure of your Personal Information as described in this Policy, do not
use our Site.
2. Types of Information We Collect.
When we refer to "Personal Information" we mean information that allows someone to identify or
contact you, including, for example, your name, address, telephone number, e-mail address, as
well as any other non-public information about you that is associated with or linked to any of the
foregoing information. When we refer to "Anonymous Information" we mean information that is
not associated with or linked to your Personal Information and which cannot be identified as
belonging to you.
We may collect Personal Information from you, such as your first and last name, mailing address,
phone number, e-mail address, billing address, credit card or debit card information, PayPal
account, and similar information when you create an account. Our Site may collect information
from you, including your browser type, operating system, IP address, web pages visited, web
pages viewed, buttons or links clicked, time spent on website, time spent on web pages, etc.
3. Use of Your Personal Information.
Whenever we collect Personal Information on our Site, we will:
• not disclose, transfer, sell or otherwise provide your Personal Information to any third
party unless required by law or as expressly stated herein;
• provide timely and appropriate notice to you about our data practices through this Privacy
• collect and use your Personal Information only with your consent, which may be express or
implied, depending on the sensitivity of the Personal Information, legal requirements, and
• collect your Personal Information only for specific, limited purposes. The information we
collect will be relevant, adequate and not excessive for the purposes for which it is
• process your Personal Information in a manner consistent with the purposes for which it
was originally collected or to which you have subsequently consented; and
• not use your Personal Information for direct marketing purposes without giving you an
opportunity to “opt-out”.
We may use Personal Information:
• to create your membership or user profile account and provide the Services you request;
• to access the third party services you specifically request access to;
• to register you for a webinar or online workshop or streaming workshop;
• to place transactions or orders to purchase software, research or membership access;
• to provide support and assistance for email requests or questions related to our Services;
• to the extent you choose to participate, to conduct questionnaires and survesy in order to
provide better Services and Products;
• to personalize marketing communications and website content based on your preferences,
access level, user level, Services purchased;
• to provide improved administration of our Site and Services including billing, mailing,
email, phone number, name updates or edits;
• to send you administrative e-mail notifications and other Services related communications;
• to send newsletters, surveys, offers, and other promotional materials related to our
Services and for other marketing purposes;
• to contact you regarding opportunities to compensate you for your algorithm's
• to share anonymized and/or aggregated algorithm performance statistics with third
parties, for example potential investors or for marketing purposes; and
• to market our products and services (and those of third parties) to you that we believe may
be of interest, both on and off the Site.
• to facilitate communication with other Members of the Site as you direct us through the
4. Control and Retention of Personal Information.
We will periodically send you free newsletters and e-mails that directly promote the use of our
Site or Services. When you receive newsletters or promotional communications from us, you may
indicate a preference to stop receiving further communications from us and you will have the
opportunity to "opt-out" by following the unsubscribe instructions. Even if you opt-out of
receiving marketing related email messages, we will continue to send you service related
provide the services, products and information you request or as permitted by applicable law.
5. Security of Personal Information.
Your Personal Information will generally be stored in our or our servers (which are hosted by a
third party service provider) located in the United States. To the extent required by law, if your
Personal Information will be transferred outside of this country, an appropriate notice will be
provided. We maintain safeguards to protect the confidentiality, security and integrity of your
Personal Information. However, as is the case with all computer networks linked to the Internet,
we cannot guarantee the security of information provided over the Internet and will not be
responsible for breaches of security unless we have acted in a grossly negligent manner.
6. Use of Anonymous Information.
We may create Anonymous Information records from Personal Information by excluding any
information that makes the information personally identifiable to the data subject. We use this
Anonymous Information to so that we may enhance the content of our Services and improve Site
performance. We reserve the right to use Anonymous Information for any purpose and disclose
Anonymous Information to third parties at its sole discretion.
7. Third Party Service Providers.
We use software plugins and other third-party plugins on this site in order to facilitate and support our
business and users. These plugins include payment gateways and other payment transaction processors,
analytics and website tracking software, membership management and access delivery software,
commenting and forum software, marketing and promotion software as well as video, audio, content, and
social media plugins. The current list of active software plugins and third-party plugins we use on this site
include: Google Analytics, Facebook, LinkedIn, Instagram, Vimeo, Pinterest, Stripe, PayPal, Disqus,
OptimizePress, Co-Schedule, SEO Yoast, YouTube, Sumo, Amazon Web Services, Digital Ocean, Comodo
Security Services, GoDaddy, Kraken Image Optimizer, Muut, Nav Menu Roles, My Page Order, Postman
SMTP, Pretty Links, Really Simple SSL, Scarcity Builder, ShiftNav, Smart Podcast Player, UpdraftPlus,
Askimet Anit-Spam, AnsPress, Sensei, WPBakery, AffiliateWP, EasyTables, Font Awesome, Post Expirator,
Remove Query Strings, Thrive Quiz Builder, TinyMCE, Visual Composer, We Total Cache, WordPress
Importer, WP User Avatar, WebinarJam, Demio, SpeakPipe, OptinMonster, Join.me, LeadPages, SendHub,
Calendly, SoundCloud, Libsyn, iTunes, GooglePlay, iHeart Radio, Stitcher, ActiveCampaign, MailChimp,
In general, the third-party providers used by us will only collect, use and disclose your information to the
extent necessary to allow them to perform the services they provide to us as already outlined in the "We
may use Personal Information" section above. However, certain third-party service providers, such as
payment gateways and other payment transaction processors, have their own privacy policies in respect to
the information we are required to provide to them for your purchase-related transactions. For these
providers, we recommend that you read their privacy policies, so you can understand the manner in which
your personal information will be handled by these providers. In particular, remember that certain providers
may be located in or have facilities that are located a different jurisdiction than either you or us. So, if you
elect to proceed with a transaction that involves the services of a third-party service provider, then your
information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities
In certain, limited circumstances we may required share or transfer Personal Information to other
unrelated third parties. For example, we may provide Personal Information to a third party: (i) at
your request; (ii) to comply with a legal requirement or court order; (iii) to investigate a possible
crime, such as identity theft; (iv) in connection with the sale, purchase, investment in, merger,
reorganization, liquidation or dissolution of our company or business; or (v) under similar
circumstances. If such an event occurs, we will take appropriate steps to protect your Personal
8. Third Party Websites.
Our Site may contain links to Internet sites that are not operated by us. These links are provided
as a service and do not imply any endorsement of the activities or content of these sites, nor any
association with their operators. We do not control these Internet sites and we are not and cannot
be responsible for their content, security, or privacy practices. We urge you to review the privacy
policy posted on those other websites you visit before using the site or providing Personal
identifiable information you submit while on our site. We may use both session ID cookies and
persistent cookies. We may use session cookies to make it easier for you to navigate our site. A
session ID cookie expires when you close you browser. A persistent cookie remains on your hard
drive for an extended period of time. You can remove persistent cookies by following directions
provided in your Internet browser’s “help” file. If you reject cookies, you may still use our site.
stored on a user’s computer for record-keeping purposes.
10. Users Outside of the United States.
If you are a non U.S. user of the Site or Services, by visiting the Site and/or providing us with
information, you acknowledge and agree that your Personal Information may be processed for the
in the country in which it was collected and in other countries, including the United States, where
laws regarding processing of Personal Information may be less stringent than the laws in your
country. By providing your information, you consent to such transfer.
We take reasonable measures to help protect information about you from loss, theft, misuse, and
unauthorized access, disclosure, alteration, and destruction.
Transfer of Information to the U.S. and Privacy Shield
We are based in the United States and the information we collect is governed by U.S. law. By accessing or
using the Service or otherwise providing information to us, you consent to the processing, transfer, and
storage of information in and to the U.S. and other countries, where you may not have the same rights and
protections as you do under local law.
We comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield
Framework as set forth by the US Department of Commerce regarding the collection, use,
and retention of personal information from European Union member countries and
Switzerland transferred to the United States pursuant to Privacy Shield. We have certified
that we adhere to the Privacy Shield Principles with respect to such data. If there is any
Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about
the Privacy Shield program, and to view our certification page, please visit
With respect to personal data received or transferred pursuant to the Privacy Shield
Frameworks, We are subject to the regulatory enforcement powers of the U.S. Federal
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to
obtain our confirmation of whether we maintain personal information relating to you in the
United States. Upon request, we will provide you with access to the personal information
that we hold about you. You may also may correct, amend, or delete the personal
information we hold about you. An individual who seeks access, or who seeks to correct,
amend, or delete inaccurate data transferred to the United States under Privacy Shield,
should direct their query to firstname.lastname@example.org. If requested to remove data, we will
respond within a reasonable timeframe.
We will provide an individual opt-out or opt-in choice before we share your data with third
parties other than our agents, or before we use it for a purpose other than which it was
originally collected or subsequently authorized. To request to limit the use and disclosure
of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful
requests by public authorities, including to meet national security or law enforcement
Our accountability for personal data that we receive in the United States under the Privacy
Shield and subsequently transfers to a third party is described in the Privacy Shield
Principles. In particular, we remain responsible and liable under the Privacy Shield
Principles if third-party agents that it engages to process the personal data on its behalf
do so in a manner inconsistent with the Principles, unless we prove that we are not
responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about
your privacy and our collection or use of your personal information transferred to the
United States pursuant to Privacy Shield. European Union and Swiss individuals with
Privacy Shield inquiries or complaints should first contact us by email at
firstname.lastname@example.org or via post at:
Option Alpha / Alta5
1600 West Ave #301
Miami, FL 33139
We have further committed to refer unresolved privacy complaints under the Privacy
Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY
SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely
acknowledgment of your complaint, or if your complaint is not satisfactorily addressed,
please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to
file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain
conditions, you may invoke binding arbitration for some residual claims not resolved by other
redress mechanisms. See Privacy Shield Annex 1 at
12. Your Rights and Choices Under GDPR
You may update, correct or delete information about you at any time by requesting such deletion at
You may exercise your right to withdraw your consent to the Service at any time. The withdrawal of consent
will require deactivation of your account. To withdraw consent and deactivate your account, please contact
support at email@example.com. If you wish to exercise your right to data portability or right to erasure,
please email us at firstname.lastname@example.org, but note that we may retain certain information as required by
law or for legitimate business purposes.
We may also retain cached or archived copies of information about you for up to 12 months. You have the
right to lodge a complaint with a supervisory authority.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of
Supervisory Authorities is available here: http://ec.europa.eu/justice/dataprotection/
bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please
contact us using the contact information provided below and we will consider your request in accordance
with applicable law. In some cases our ability to uphold these rights for you may depend upon our
obligations to process personal information for security, safety, fraud prevention reasons, compliance with
regulatory or legal requirements, or because processing is necessary to deliver the services you have
requested. Where this is the case, we will inform you of specific details in response to your request.
Our Services and Site are not directed to children and children are not eligible to use our Services.
Protecting the privacy of children is very important to us. We do not collect or maintain Personal
Information from people we actually know are under 13 years of age, and no part of our Site or
Services is designed to attract people under 13 years of age. If we later learn that a user is under
13 years of age, we will take steps to remove that user's Personal Information from our databases
and to prevent the user from utilizing the Site and the Services.
14. Changes in this Privacy Statement.
homepage, and other places we deem appropriate so that you are aware of what information we
collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right
to modify this privacy statement at any time, so please review it frequently. If we make material
changes to this policy, we will notify you here, by email, or by means of a notice on our home page.
15. Contact Us.
email@example.com, or mail us at:
Option Alpha / Alta5
17 Palermo Ave
Coral Gables, FL 33134
Notice to California Residents:
If you are a California resident, California Civil Code Section 1798.83 permits you to request information
regarding the disclosure of your Personal Information by High Fidelity to third parties for the third parties'
within the State of California. To make such a request, please send an e-mail to firstname.lastname@example.org or
write us at the address listed immediately above.
Last Revised: January 10, 2019