Privacy Policy
Effective date: May 5, 2020
Emissaries of Divine Light (EDL) is located at Sunrise Ranch, 100 Sunrise Ranch Rd., Loveland, CO 80538, USA, and operates this website: https://test.win-win.com.ua. We are committed to protecting the privacy and security of your personal information.
This Privacy Policy will inform you of our policies regarding the collection, use and disclosure of your personal data when you use our website, and the rights you have associated with your data. Any questions or concerns can be directed to the EDL Data Protection Officer at dataprotectionofficer@emnet.org .
We use your data to optimize performance of our website and provide our services to you. By using our website, certain data will need to be collected to support that use and access. Where the collection and processing of your data is necessary for the pursuit of a legitimate purpose, we may process certain data without obtaining consent if so permitted by law. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://test.win-win.com.ua.
Definitions
Service
Service or “website” is the https://test.win-win.com.ua website operated by Emissaries of Divine Light.
Personal Data
Personal Data or “your data” or “personal information” means the data about you, and any personal information that can be used to identify you (and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is either data collected automatically, generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small files stored on your device (computer or mobile device).
Data Controller
Data Controller means the company or person that determines the purposes for which and the manner in which any personal information is, or is to be, processed (which means “used”). For the purpose of this Privacy Policy, EDL is the Data Controller of your Personal Data.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any company or person who processes the data on our behalf. We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any person using our website and is the subject of the Personal Data collected by us.
Information Collection and Use
We collect several different types of information to provide and improve our website for you and your use.
Types of Data Collected
Personal Data
While using our website, we may request certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally, identifiable information collected by our website includes the following:
E-mail address
First and last name Phone number
Address, State/Province, ZIP/Postal code, City, Country
Cookies and Usage Data
We may use your Personal Data to contact you with specifically requested services, such as EDL subscriptions, newsletters, marketing or promotional materials, and other information requested by you.
Usage Data
We also collect information on how our website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. Such personally identifiable data is required for access and use of EDL’s website.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
You can update the settings on your browser to refuse all cookies. However, please note that if you do not accept cookies, you may not be able to use some parts of our website or it may affect the speed at which our website will load.
Cookies we use are:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Use of Data
EDL does not sell any personal information or personal data collected from this website. EDL only uses the collected data for internal purposes, including:
To provide and maintain our website
To notify you about changes to our website
To allow use of interactive features of our website when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our website
To monitor the usage of our website
To detect, prevent and address technical issues
To provide essential security features for our website
To provide you with EDL news, special offers and general information about other goods, services and events as specifically requested through EDL’s website. If you do not wish to continue to receive such requested materials from EDL, you may withdraw your request at any time. What we offer is similar to those that you have already purchased or inquired about, unless you have opted not to receive such information.
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
As required by the GDPR, EDL has a legal basis for collecting and using the limited personal information collected through our website. Where necessary, EDL will adjust our processing of your personal data to ensure compliance with the GDPR.
EDL’s legitimate and legal basis for processing your data occurs when:
EDL must fulfill and perform under a contract with you
You have given us permission or consent to do so
The processing is in our legitimate interests and it is not overridden by your rights
For payment processing purposes
To comply with the law
Where the legal basis for us processing your personal data is that you have provided your consent, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent. You can withdraw your consent by contacting the Data Protection Officer at dataprotectionofficer@emnet.org
Retention of Data
EDL will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
EDL will also retain limited Usage Data for internal analysis purposes. Usage Data is not retained beyond the duration of the session, except when we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.
EDL employs all reasonable measures to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of an EU data subject’s Personal Data to an organization or a country will occur unless 1) the country to which personal data will be transferred has been granted a European Commission adequacy decision, 2) the recipient of the personal data is located in the US and has certified to the US-EU Privacy Shield Framework or 3) we have put in place appropriate safeguards, such as requiring and complying with EU standard contractual clauses with the recipient, or the recipient is a party to binding GDPR compliant corporate rules. If any such transfers are made, EDL will inform you to whom and to where your information was transferred in a timely, reasonable manner.
You may request more information about the safeguards in place by contacting our Data Protection Officer: dataprotectionofficer@emnet.org .
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, EDL may be legally obligated to disclose your Personal Data, such as in response to verified requests by public authorities (e.g. a court or a government agency).
Legal Requirements
EDL may disclose your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend EDL
Prevent or investigate possible wrongdoing in connection with the website
Protect the personal safety of users of the website or the public
Protect against legal liability
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the EU or the European Economic Area (EEA), you have certain data protection rights. EDL will take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact the DPO at dataprotectionofficer@emnet.org.
EU or EEA residents have the following data protection rights:
The right to access, update, or delete the information we have on you.
You have the right to access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information corrected if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to a copy of the information we have on you in a structured, readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where EDL relied on your consent to process your personal information.
Please note we will require that you verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority, a link to which can be found at https://edpb.europa.eu/about-edpb/board/members_en in the European Economic Area (EEA).
Service Providers
We employ third parties to provide our website (“Service Providers”) on our behalf, perform website-related services, or assist us in analyzing how our website is used.
These third parties have access to your Personal Data only to perform limited and EDL-authorized tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
Third-party Service Providers are used to monitor and analyze the use of our website.
Google Analytics
Google Analytics, offered by Google, tracks and reports website traffic. Google uses the data
collected to track and monitor the use of our website.
This data is shared with other Google services. Google uses collected data to personalize ads of its own advertising network.
You can opt-out of having your activity on EDL’s website provided to Google Analytics by installing the Google Analytics opt-out browser add-on: https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Behavioral Remarketing
If you have requested or consented to receiving EDL’s marketing materials, certain third party websites will advertise to your visit to our website. EDL and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service. You may adjust what cookies are collected and used by EDL
Twitter remarketing service is provided by Twitter, Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions here: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page.
Facebook remarketing service is provided by Facebook, Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA at http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada at http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe at https://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Payments
We may provide paid products and/or services on our website. To do so we use third-party services for payment processing (e.g. payment processors).
We do not and will not store or collect your payment card details. That information is provided directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
Stripe
Their Privacy Policy can be viewed at https://stripe.com/us/privacy
PayPal / Braintree
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us to delete this information. When we become aware of certain unknown collected Personal Data from children without verification of parental consent, we will take all steps necessary to remove that information from our servers. If you believe we have inadvertently collected or been provided information for someone under the age of 18, please contact our DPO at dataprotectionofficer@emnet.org.
Changes to This Privacy Policy
We review and/or update our Privacy Policy annually. If you have provided an e-mail to EDL, we will in a timely and reasonable fashion notify you of any changes directly by e-mail. Otherwise, any changes to our Privacy Policy will be prominently noted on our home page and the new Privacy Policy will be posted on this page.
We will also update the “effective date” at the top of this Privacy Policy.
Please check in regularly for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us by visiting this page on our website: https://attunement.org/contact or by e-mail to our Data Protection Officer at dataprotectionofficer@emnet.org.
DATE LAST MODIFIED: June 9, 2020
