ASPIRE TO BE WEBSITE PRIVACY POLICY

This Privacy Policy explains how we collect, use, disclose, and transfer information about users who interact with us including (but not limited to) via our websites, social media accounts, and downloadable applications, such as mobile apps. This policy also tells you how we use tracking technologies, cookies and browsing data we collect from your use of our online services, the measures we take to protect the security of the information you provide to us through our online services, and how you can contact us if you have any questions regarding our online services (including if you want to unsubscribe from our services or update your contact details). Information about how Aspire To Be processes your information outside our online services (e.g. working for Aspire To Be or visiting Aspire To Be premises) is available by contacting https://aspiretoobe.com/privacy-policy.

Aspire To Be does sell or plan to sell consumer personal information. Please see below for the categories of information, categories of sources, the business/commercial purposes for which personal information is collected, and third parties with whom we share such personal information.

If you are a resident of California, you have the right to (1) request that Aspire To Be disclose what personal information it collects, uses, discloses, and sells; (2) request the deletion of your personal information collected or maintained by Aspire To Be; and (3) request to opt-out of the sale of your personal information by Aspire To Be. Please see below for instructions on how to request disclosure and deletion of your personal information by Aspire To Be, as well as how to opt-out of the sale of your personal information.

In the preceding 12 months Aspire To Be has disclosed and sold consumer personal information to third parties for business and/or commercial purposes. Further, in the preceding 12 months, Aspire To Be has not knowingly sold personal information of minors under the age of 16 without affirmative authorization.

LAST UPDATED: AUGUST 27, 2022

1. SCOPE AND CONSENT

When you use our online services, you are contracting with Aspire To Be.  If you reside outside of the United States, Aspire To Be is your data controller.  By using our online services, you expressly consent to our collection, use, disclosure, and retention of your information relating to you including personal information as described in this Privacy Policy.

2. TYPES OF INFORMATION WE COLLECT

Our goal is to collect and use information to deliver effective and personalized services, which take your interests and preferences into account, as well as for our legitimate business needs and interests.

There are two main types of information we collect about users of our online services that include (but are not limited to) the following:

• Information that identifies you: this is commonly referred to as “personal information” and includes, for example, information that you provide to us such as your name, home address, age, gender, telephone number, email address, payment information (including your credit card number), and/or photos or video footage of you; and
• Information that relates to you, but on its own does not identify you: such as information about your Internet connection, the equipment you use to access our online services, and information relating to your usage of those services.

The main categories of information we collect about our online services users include (but are not limited to) the following:

• Contact/Registration information: for example, your telephone number or email address, if you have subscribed to a service such as program updates; name, age, gender, or interests if you register for an account on one of our online services; delivery address if you buy a product or service through an online service; or your age, location, or delivery address if you choose to enter a competition or sweepstakes offered through our online services.
• Transaction information: when you order products or services through our online services, you may provide information such as your credit/debit card details and other personal information related to that transaction.
• Information that you provide on message boards and other user forums: including your username, images, or videos.  Please use caution when posting to messages boards or other forums, as information posted to these portions of our online services is public information.
• Information about your equipment and about your interactions with Aspire To Be and other online services: for example, your Internet protocol or IP address; pages, content, or advertising that you visit within online services (including online services not provided by Aspire To Be); or the type and version of your device’s operating system or web browser, your device ID, and in some instances, your device’s location.
• Information that is collected from social networks and publicly available data: if you visit our online services on a device through which you also interact with social networks or if you interact with us through a social media function such as a plug-in (for example, a Facebook “like” button) then you may be permitting us to have on-going access to some information from your social network profile (such as your name, email address, your friend list, photo, age, gender, location, birthday, social networking ID, current city, and the people/sites you follow ). If you don’t want a social network to collect the information about you as described above, or you don’t want a social network to share it with us and other third parties, please review the privacy settings and instructions of the applicable social network before you visit and use our online services.
• Information that is collected from Consumer Data Resellers: we may collect information about you from consumer data resellers, including but not limited to, demographic and other generally available information, or advertiser information, including purchasing data and membership in loyalty programs.
• Information About Your Video Viewing Behavior: information about your video viewing behavior on our online services (e.g., content viewed and information about the advertisements within the content you have been shown or may have clicked on, etc.).

3. HOW WE COLLECT YOUR INFORMATION

The methods we use to collect information about you are as follows:

• Directly from you, when you provide it to us: for example, when you request products or services from us, when you register with us, respond to surveys, apply for a job, contact us or otherwise interact with us. Please remember that if others use devices into which you remain logged in, they may share information with us as if they were you, and they may have access to information that you have previously provided us.  To protect your privacy, please log out from our online services that you access from public or shared devices.
• Automatically, when you use our online services: information collected through the use of cookies and other technologies, and when you download our mobile apps.
• From third parties: including social networks, other online services, publicly available records, our service providers, and from consumer data resellers.

4. HOW WE USE YOUR INFORMATION

We (and our service providers) use information to:

• provide the online services you have requested;
• enter you into sweepstakes, contests or promotions where requested;
• create an online services account if you have requested one;
• personalize the services offered by us or our affiliates, including providing personalized advertising on some online services;
• respond to your inquiries, requests, and comments;
• allow you to participate in the interactive features of our online services, where you choose to do so;
• provide technical support for our online services;
• prevent fraud or potentially illegal activities (including copyright infringement) on our online services;
• protect the safety of users and others on our online services;
• enforce our online services’ terms of service;
• understand how our online services are used so that we can continuously improve them, and the services we provide to you;
• send you newsletters and information about products, services and promotions relating to us and/or our business partners or other organizations that we work with, in accordance with your communication preferences.
• send you service-related communications, including announcements and administrative messages;
• create anonymous and, where legally permissible, personally identifiable user and consumer profiles, and audience segments that can be used for targeted advertising and marketing, and subject to legal restrictions (including consent where necessary) we may also use technology (such as Facebook Custom Audiences) to deliver advertising to you on other sites and in mobile apps based on the email address or other personal information you provide to us or through the use of information we receive from third parties, including Consumer Data Resellers.
• if you use our online services to send gifts we use the contact information (e.g., email addresses) that you provide to send the gift to your requested recipients, provide other communications relating to those sorts of transactions, as well as any further communications as may be authorized by the recipients; and implement any related social networking features you have activated.

Note that we may combine all the information we collect or receive about you for any of the foregoing purposes.

5. HOW WE SHARE YOUR INFORMATION

Information sharing within Aspire To Be and among Aspire To Be Affiliates.

• Your information may be shared with Aspire To Be affiliates, and used to help us better tailor our services, products and advertising to you.

Information sharing with third parties – e.g. service providers, advertisers, consumer data resellers, social networks:

• Service providers that we have retained to perform certain business-related functions on our behalf: for example, service providers who offer services including research and analytics; hosting websites, fulfilling transactions, maintaining databases, administering contests, providing technology services and platforms, and processing payments.  These parties are provided only with the personal information or other information they need to perform their functions and can only use and disclose that information as is necessary to perform the services on our behalf, or to comply with legal requirements. We take steps to ensure that third party service providers will take appropriate steps to protect your personal information.
• Social Networks: You may interact with certain features of our online services that cause information to be published to your social networks.  For example, you may click on a Facebook “like” button, which publishes to your Facebook account that you “like” one of our stories or social media posts on other platforms.  On pages of our online services that contain social network functionality, the social network providing the functionality may be able to collect information about you, even if you don’t use that functionality. For example, if a page within our online services contains a Facebook “like” button, Facebook may be able to collect data about your visit to that page, even if you don’t click on the “like” button. To control this sharing of information, please review the privacy policy of the relevant social network and/or log out of it before you use our online services.
• For Mobile Apps: In mobile apps, your personal information and information about how you use our mobile apps may be shared with technology providers, carriers, analytics providers, and/or other mobile apps either operated by us or third parties.
• Advertisers, Advertising Networks and Consumer Data Resellers: Some online services, including mobile apps, may be supported with advertising, and collect data to help our online services serve ads.  This helps keep the cost of online services low or free. We work with advertisers and third-party advertising networks and consumer data resellers that buy and/or sell information to other companies for multiple purposes including offering products and services that may interest you. These third parties may receive information about how you interact with content and advertising provided in our online services. These third parties may view, edit or set their own tracking technologies/cookies, which will allow them to collect information about you.
• Sharing of Video Viewing Behavior: we may share information (and you agree to this sharing) about the video content you view on our online services with video measurement services, analytics providers and advertising companies, and third party social media sites. This sharing shall continue for two years or until you withdraw your consent. Information that may be passed to video measurement services, analytics providers and advertising companies may be via cookies and tracking technologies.

Information sharing with other parties:

In addition, we may disclose your personal information to law enforcement agencies, government/regulatory bodies, and content protection organizations to:

• Protect our legal rights, privacy or safety, and that of our subsidiaries, affiliates, employees, agents, contractors, or other individuals;
• Protect the safety and security of visitors to our online services or other properties;
• Protect against fraud or other illegal activity or for risk management purposes;
• Respond to inquiries or requests from government, regulatory, law enforcement, or public authorities;
• Permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages that we may sustain;
• Comply with the law including with subpoenas, search warrants, court orders, and other legal process; or
• Enforce applicable terms of service.

Sale or transfer of all or part of our business or assets

We reserve the right to transfer the information described in this Privacy Policy in the event we sell or transfer all or a part of our business or assets so that the buyer can continue to offer you the online services. We will make commercially reasonable efforts to provide you with reasonable notice of such transfer, or as otherwise required by law. If you do not want your personal information to be processed following such a transfer, you should contact the subsequent owner of the business.

Parties that we have shared information with

For more information on which parties we have shared information with, please visit https://aspiretoobe.com/privacy-policy

• Except where otherwise indicated. we do not knowingly collect or store any personal information from children under the age of 13. Some of our online services may attract an audience that is under the age of 13. For those services, we use an age-gate to make certain features unavailable for use by children under 13, and we do not knowingly collect personal information from children under 13 in connection with those features. Where required, we will provide notice to and obtain verifiable consent from parents or guardians for the collection of personal information from children under 13, and provide parents or guardians the ability to request access to personal information we have collected from their children. We encourage parents and guardians to spend time with their children online and to be fully familiar with the online services used by their children. If a parent or guardian becomes aware that his or her child under 13 has provided us with information without his or her consent, he or she should contact us at https://aspiretoobe.com/privacy-policy. As required by law, we will delete such information from our files within a reasonable time.
• Except where otherwise indicated, we do not knowingly collect or store any personal information from children under the age of 16. Where required, we will provide notice to and obtain affirmative authorization and verifiable consent from the user for the collection of personal information from children between the ages of 13 and 16. Children between the ages of 13 and 16 must affirmatively consent to the collection of their personal information. If such users elect to opt-in to the sale and/or collection of personal information, Aspire To Be shall provide notice of a right to opt-out at a later date and the process of doing so.
• For certain websites covered by this Privacy Policy and involved in e-commerce, you may only be able to use that site and any related services if you are 18 years of age or older, or the age of majority in your jurisdiction of residence, whichever is older. If you are under the age of 18 or the age of majority in your jurisdiction of residence, you may only use that site and any related services with the involvement of a parent or legal guardian.

California minors under 18 years old may request the removal of any information that they posted to Aspire To Be sites by contacting https://aspiretoobe.com/privacy-policy. Upon such request, Aspire To Be will anonymize, or remove from public view, any content posted by a minor to one of its websites, unless required by law to retain such content or information.

7. HOW WE PROTECT YOUR INFORMATION

We maintain procedural, technical, and physical safeguards for our online services to help protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of the personal information you provide via our online services. We also ask the service providers that help us deliver our online services to do the same. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop, or improve our online services. Unfortunately, no transmission of data is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. Therefore, any transmission of personal information to us is made at your own risk. If you believe that your interaction with us is no longer secure, please notify us using the contact details below.

Usernames & Passwords

It is important that you protect and maintain the security of any account you create and that you notify us immediately of any unauthorized use of any Aspire To Be account.  Do not disclose your password to anyone else.

8. YOUR RIGHTS AND CHOICES

Communication Preferences and Opt-outs

If you have subscribed to one or more of our email newsletters or are receiving them from us and you don’t want them anymore, you can unsubscribe. Select the “unsubscribe” link at the bottom of any message, by other means provided to unsubscribe, or using the contact details below, to unsubscribe from marketing and promotional emails and associated marketing delivered to you on third party services based on your subscription data.  However, you cannot unsubscribe from some service-related messages.

Access and Correction

In addition to the functionality provided to you via our online services (such as using “account settings” for registered users), where legally required we provide online visitors with access to their personal information and the ability to review, update and correct it. Consumers have the right to request that Aspire To Be disclose what personal information it collects, uses, discloses, and sells.

Some access requests may be subject to a small fee. To help preserve your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, and possibly photo ID before granting access to your personal information.  Please contact https://aspiretoobe.com/privacy-policy for more information about exercising these rights.

Data Retention and Deletion

We will retain your data for as long as you use our online services and for a reasonable time thereafter. If you’d like to delete, modify or update the data that you provided via our online services please use the settings on our online services or contact us at https://aspiretoobe.com/privacy-policy we will respond within a reasonable time.

To help preserve your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, and possibly photo ID before granting access to your personal information. Deletion requests shall be done in a two-step process: (1) users will submit request for deletion and (2) users will separately confirm the personal information to be deleted.

Please note that some or all of this data may be required in order for our online services to function properly, and we may be required, by law, to retain certain information.

Right to Non-Discrimination

Under California law, a consumer has a right not to receive discriminatory treatment by a business for the exercise of his or her privacy rights under the California Consumer Protection Act (CCPA).

Authorized Agent

A consumer may designate in writing an authorized agent to make a request under the CCPA on the consumer’s behalf. Please contact us at https://aspiretoobe.com/privacy-policy if you would like to designate an authorized agent to make a request under the CCPA on the consumer’s behalf and we will respond within a reasonable time.

To help preserve your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, and possibly photo ID before granting access to your personal information. We will also take reasonable steps to verify the identity of your authorized agent, such as requiring ID, unless you have provided your agent with power of attorney pursuant to Probate Code sections 4000 to 4465.

9. WHERE YOUR INFORMATION WILL BE USED

Aspire To Be is based in the United States and may from time to time transfer your personal information to other countries and make it accessible to any of our affiliates and third party service providers internationally. Where the transfer of information is to a country that does not provide an adequate level of information protection, Aspire To Be has taken steps to ensure that your personal information receives an appropriate level of protection.

If you are located outside of the United States, please be aware that information we collect, including personal information, may be transferred to, and processed, stored and used in the United States.  Under United States law, your personal information may be subject to access requests from governments, courts, or law enforcement in the United States.

By using our online services and providing your personal information to us, you understand and agree that your personal information may be sent to other countries including those which do not provide an equivalent level of information protection as the European Economic Area (EEA).

10. IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS 

Residents of the State of California may request a list of all third parties to which our online service has disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes.  If you are a California resident and want such a list, please contact us at Aspire To Be, at https://aspiretoobe.com/privacy-policy. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code.  In the body of your request, please provide enough information for us to determine if this applies to you.  You need to attest to the fact that you are a California resident and provide a current California address for our response.  Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Do Not Track

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Aspire To Be responds to “Do Not Track” browser settings. Aspire To Be does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

11. LINKS TO OTHER ONLINE SERVICES

Our online services may contain links to third party websites/services for your convenience and/or information (for example, to sites which are provided by our third party vendors).  If you access other online services using the links provided, you may leave Aspire To Be’s online services. When you access these other sites, even ones that may contain Aspire To Be logo, please understand that the operators of these websites may collect information from you which will be used by them in accordance with their privacy policies and Terms of Use, which may differ from ours. We do not endorse or control the policies or practices of third party websites that we do not control or operate.

You should always carefully read the privacy policy of any website you access in order to understand their specific privacy and information usage practices.

12. UPDATES TO OUR PRIVACY POLICY 

From time to time, we may revise this Privacy Policy to reflect industry initiatives, changes in the law or technology, or changes in our practices regarding information collection and use.  If we make material revisions to the way we collect or use your personal information so that we are using it for purposes or sharing data with third parties that you have not consented to, we will provide you with notice of those changes and may do so by either: (1) announcing the change on the home page of our websites or (2) taking other actions as we deem appropriate under the circumstances, including without limitation, posting the revised version of this Privacy Policy online. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on our online services. You should check our online services frequently for updates.

You can determine when this Privacy Policy was last revised by referring to the “Last Updated” or similar legend at the top of this page. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the Internet, accessible through this site. By continuing to use this online service following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, as it may be amended from time to time, in whole or in part, please do not continue to use our online services.

13. CONTACT US

For any queries or complaints in relation to this Privacy Policy or Aspire To Be’s privacy practices, please contact us at https://aspiretoobe.com/privacy-policy. Special Note Regarding Sweepstakes, Raffles, Giveaways, Promotions, Contests, etc.