document: title: privacy policy
text: PRIVACY POLICY 

Modification Date: May 16, 2018

Effective Date: June 16, 2018

Hi. Pat here. Just like you, I care about the use of my personal information online, so it is only fair I provide you with insight into the privacy practices employed here at SmartPassiveIncome.com. Particular areas of the world now require different privacy disclosures, so please read the entire policy to make sure you understand our practices fully. 

I. If You are Located In the EU

A. What Personal Data Do We Collect From You?

Personal data is information that can be used to identify you such as your name, IP address, and email address. As a business, we collect personal data from you in a number of ways including:

(1.) Opt-In To Email Course: Your name and address.

(2.) Waiting List: Your name and address.

(3.) Transaction: You name, email address, billing information and payment source.

(4.) Submitting Questions: Your name, email address, and question.

(5.) Join My Book Club: Your name and email address.

(6.) Lessons: Your name and email address.

B. What Is The Purpose of Processing Your Personal Data?

We collect the information above for the following purposes. 

(1.) Opt-In To Email Course: To provide you with information on the course in question and the topic in general.

(2.) Waiting List: To let you know when a course or service opens or is closing.

(3.) Transaction: To process a purchase you make with us.

(4.) Submitting Questions: To answer questions you might have for us.

(5.) Join My Book Club: To send you messages regarding books Pat has read and reviewed.

(6.) Lessons: To send you lessons you are interested in.

C. What Legal Basis Do We Have For Collecting and Processing Your Information?

Websites must have a legal basis for collecting information from individuals located in the European Union. Our legal basis for each of the ways we collect information from you is as follows. Please note where consent forms the basis, you can withdraw consent at any time by contacting Jessica Lindgren opting out of any email message using the “unsubscribe” link.

(1.) Opt-In To Email Course: We will ask for your consent first. 

(2.) Waiting List:  We will ask for your consent first.

(3.) Transaction: We will collect your information as part of a legal contractual transaction.

(4.) Submitting Questions: We have an allowed legitimate interest in providing a response to your questions and need to use your data to do so. We will not use the data for other purposes. 

(5.) Join My Book Club:  We will ask for your consent first.

(6.) Lessons:  We will ask for your consent first.

“Legitimate interests” for processing your personal information exist where you submit the information with an expectation that it will be processed and there is no undue impact on you. If you disagree or have questions, please contact Jessica Lindgren at support@smartpassiveincome.com and we will cease the processing of your data under this legal basis.

D. Who Has Access To The Data We Collect?

We process and access to the data we collect from you. However, we use third parties to assist us with processing your personal data including the following categories of recipients:

  * Financial transaction processors (processing your payments)
  * Customer service communication platform
  * Contest and survey platform
  * Email communication manager
  * Marketing funnel providers
  * Website management services
  * Website design and programming services



These third parties have signed contract with us in which they are prohibited from utilizing, sharing or retaining your personal data for any purpose other than we dictate. 

E. Cookies and Similar Technologies

This site uses cookies and similar technologies to track particular aspects of you and other people who visit us. This tracking is done to provide us with information on how people move about the site, what is of interest to them and what is not, how our marketing is performing, and incidental items such as what percentage of users access the site from a personal computer versus a mobile phone. You may block most cookies by adjusting your browser settings as well as responding to the cookie consent notice that appears when you visit this site. To learn more about this technology, please visit our Cookie Policy.

F. How Long Do We Keep Your Data?

We keep your personal data for different periods of time depending on the reason it was gathered in the first place.

(1.) Opt-In To Email Course: 36 months

(2.) Waiting List: 24 months

(3.) Transaction: Four years for tax audit purposes.

(4.) Submitting Questions: Five years 

(5.) Join My Book Club: 36 months

(6.) Lessons: 26 months

If a legal claim arises involving your data, we will store and disclose that data until the matter has resolved. 

G. Your Right To Ask For Corrections, Erasure, And Export Of Your Data

You have the right to control your personal data. Specifically, you have the following rights: 

  * The right to be informed: We are informing you now with this policy.
  * The right of access: We’ll provide you with the data we have about you.
  * The right to rectification: Request we fix incorrect data about you.
  * The right to erasure: Request we erase certain data about you.
  * The right to restrict processing: Ask us to restrict certain type of processing of your personal information.
  * The right to data portability: Ask us to provide your personal data we have for export.
  * The right to object: Object to how we use your data.
  * Rights in relation to automated decision making and profiling: We don’t profile you, but keep in mind you have this right with other sites.



To exercise any of these rights, please contact Jessica Lindgren at support@smartpassiveincome.com with your request.

H. Your Right To Withdraw Consent

Although this is mentioned above, we want to emphasize that wherever we’ve asked for your consent to collect or process your personal data, you have the right to withdraw that consent. If you receive email messages from us, you can use the “unsubscribe” link in each message to withdraw consent and stop the mailings. Alternatively, you can contact Jessica Lindgren at support@smartpassiveincome.com with your request. 

I. Do We Transfer Your Data To Third Countries?

No. We are located in the United States. Your data is collected and held here. 

J. Privacy Concerns, Contacting Us, Complaints.

You can contact Jessica Lindgren at support@smartpassiveincome.com with your request with any questions or requests you have about these policies or your personal data. If, after contacting us, you feel a privacy issue has not be resolved, you have the right to file a complaint with a Supervisory Authority such as the Data Protection Commissioner of Ireland.

Data Controller

Representative: Pat Flynn

SmartPassiveIncome.com

11315 Rancho Bernardo Road, Ste 126

San Diego, CA 92127

You can also send correspondence by traditional mail to SmartPassiveIncome.com, 11315 Rancho Bernardo Road, Ste 126, San Diego, CA 92127

II. For Our Friends Located In California

A. Do Not Track Signals.

Pursuant to the California Online Privacy Protection Act, we hereby disclose that we do not currently honor “do not track” signals issued by browsers or other third party sources.

B. California Eraser Law.

If you are an individual under 18 and have provided personal information or content to us in some manner, you have the right to request the deletion of that information pursuant to the “California Eraser Law.”  Contact us to make such a request at support@smartpassiveincome.com.

III. For All Our Valued Friends Regardless of Location

A. Privacy Policy Modifications and Updates.

We may update and modify this Privacy Policy at any time. In doing so, we will post a notice on the site 30 days before the change goes into effect and forward an email message to you should we have an email address for you.

B. Legal Disclosures of Personal Information.

We may process, store, and disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us, (2) protect and defend our rights or property or (3) act under exigent circumstances to protect the safety of the public or users of the site.

C. DMCA Disclosures

We comply with the Digital Millennium Copyright Act of 1998. As part of the compliance process, we may be required to disclose whatever information we have for you to a copyright holder who has submitted a complaint to us. 

D. Public Comments.

You may leave comments on forum posts. Please remember that any information you provide is not private. The information can be viewed by anyone online including family, friends, the media, investigators, and potential employers conducting background checks. 

E. Third Party Websites.

We link to other sites, but please keep in mind that we do not control the privacy policies of those sites. Make sure to review the policies of any such sites before providing your personal information.

F. Sale of Business

Should we sell this site or our business, your personal information will be an asset transferred to the new owner.

If you have any questions about this Privacy Policy, please contact us.