PRIVACY, SECURITY AND TRANSPARENCY STATEMENT
Last version updated on 06/04/2024
Thank you for visiting the virtual resources published by Etison, LLC. Our privacy statement, contained in the following pages, serves to inform you about the type of personal information we collect, how we use it, with whom we share it and why, and what we do to try to protect it. We go into these issues in great detail in the following pages. We encourage you to read them in detail. In the meantime, we'll provide a quick overview below.

What do we collect?
There are two types of information we collect from your online activity, which we then store and use:
non-personal information that is automatically collected from each visitor, such as your device's operating system; and
personal information that you voluntarily provide to us or that is automatically collected.

Why do we use it?
We use non-personal information to manage our online resources, to improve them, and to make business decisions about which programs our customers might like.
We use voluntarily provided personal information to respond to your inquiries and to provide you with the services you have requested, among other uses as described below. We do not sell or rent your information to third party data providers or marketing companies. As you would expect, we will only disclose personal information when required to do so by law.

When do we share it?
We share personal information when necessary to comply with our legal obligations and when we have to comply with contracts we have with our vendors and business partners. We do not sell or rent any personal information to third parties or data brokers, or to marketing companies.

Your Choices and Privacy Rights
You do not have to provide personal information to enjoy most of our online features. In addition, you may opt out of certain activities such as newsletters and advertisements. You may have certain additional rights depending on the jurisdiction in which you reside, or in which your personal data was collected, under applicable data protection.

Contact
Questions about this highlights page or our online privacy statement may be sent to Etison, LLC, ATTN: Legal & Compliance Department, 3443 W. Bavaria Street, Eagle, Idaho 83616 or compliance@clickfunnels.com.
The English version of this privacy statement is the controlling version regardless of any translation you may attempt to make.

Virtual assets are the features of the websites we own that allow you to interact with our websites, as well as applications that we have created and distributed to allow our customers and fans to view our virtual assets or otherwise interact with the content we offer.

FROM WHOM WE COLLECT PERSONAL INFORMATION
We may collect personal information from the following groups of stakeholders: visitors and users of our online and mobile resources; our customers; current members of our workforce and those applying for posted jobs; and third-party vendors and business partners.
Personal information typically refers to information that can be used to identify you or that can be easily linked to you (e.g. your name, address, telephone number, email address, social security number and date of birth). Privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of their consumers or stakeholders that they protect. If those laws apply to us, such as in the case of The California Consumer Privacy Act ("CCPA") or The EU General Data Protection Regulation ("GDPR"), our use of the phrase "personal information" includes the unique elements required by those laws.

Categories of Information We Collect


The categories of information we collect from each of these groups, and how we use it, differ. As you may have noticed, the same person may fall into more than one group. Most of this statement addresses our processing and sharing of personal information collected from visitors and users, and from our virtual resource customers.

However, we collect and retain the types of professional or employee-related personal information that one would expect an employer to have about its current and former workforce, and new job applicants. We provide the legally required collection notices and describe our use and dissemination of personal information of our workforce and applicants in greater detail in internal confidential human resources manuals and documents accessible to our workforce members or published on the proprietary workforce/applicant portals we operate. In some cases, these portals and applications may be managed by third parties who transfer personal information to us. In these situations, the legal responsibility to provide notice rests with the third parties, not us.

Additionally, like any corporate entity, we purchase goods and services, lease equipment and office space, and attend industry events. In doing so, we interact with many existing and potential future vendors and business partners from whom we necessarily collect certain personal information connected with our contractual business relationships. We use and share personal information collected from our vendors and colleagues to manage, administer, and fulfill our contracts with them or share information about our products. We describe our use of vendors' or colleagues' personal information in more detail in the confidential contracts with those parties or in the supplier management portals we operate.
WHAT WE COLLECT

There are two types of information we obtain from your online use, which we then store and use: (i) non-personal information that is automatically saved from each visitor, such as the operating system used by your device; and (ii) personal information that you voluntarily provide to us or that is collected automatically.
By using our virtual resources or purchasing our products or services, you imply that you agree to this section of our privacy statement and that we may use and disclose your information in the manner we have described.
Information Voluntarily Provided

If you participate in certain activities through our online and mobile resources (virtual resources), you may be asked to provide us with information about yourself. The types of personal information we collect in these situations are identifiers (such as your name, email address, address, and phone number), professional information (such as your business affiliation), and financial accounting information (such as your credit card information). We do not sell, rent, or trade voluntarily provided personal information to third parties.

If you do not want us to collect this type of personal information, please do not provide it to us. This means you should not participate in the virtual activities we propose, and it would be more convenient to contact us by phone or mail. Participation is your decision only. Non-participation may limit your ability to fully take advantage of the virtual resources, but it will not affect your ability to access certain information available to the general public regarding the virtual resources.

Some examples of how you might voluntarily provide us with your personal information and how we might use it:

    Emails and Online Forms: When you send us an email or complete an online form, whether to contact us, your email along with other personal information (e.g., your home address or phone number) that may be in the content of your message or attached to it, will be retained by us and used to respond directly to you and process your request. Depending on the personal information provided, communication from us may be through emails, phone calls, and/or text messages. We may also send you information about any of our products or services we think might interest you.

    Registering for an Account: When you register for an account or register your child for a sub-account, you provide us with personal information such as your name and email address (or your child's name and email address), which we will retain. We use that information to create and manage your account and, in some cases, to set up a password and profile to communicate with you and any sub-account you have created via email.

    Registering for Events: When you register for events, conferences, or programs that we may organize ourselves (rather than subcontracting to a third-party event manager with its own privacy policies), you will be providing the types of identifiers we have described earlier. If the event requires a fee, we may request your credit card details or other financial information. We use this information to register you for the event and send you notifications about the same event.

    Subscribing to Our Service: We use any information provided by our customers to fulfill our contractual obligations and provide the products and services they have paid for, to manage their accounts, and communicate with them.

    Social Media and Community Features: Some of our virtual resources may offer community features similar to social networks, allowing users to post messages and comments, and/or upload an image or other files. If you choose to use these features, the information you upload, including your screen name and any other personal information, will be in the public domain and not covered by this statement.

Information Collected Automatically

When you visit our virtual resources, basic information is passively collected through your browser using tracking technologies, such as a "cookie," which is a small text file that is downloaded to your computer or mobile device when you access the virtual resources. It allows us to recognize your computer or mobile device and store some information about your preferences or past actions.

We allow vendors to use cookies or similar technologies to collect information about your browsing activities while you have been using the site. For example, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how you use the virtual resources and improve your experience when you visit the virtual resources. For more information on how Google uses this information, visit www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

The internet activity information collected through cookies and other similar means includes things like: the domain name and IP address from which you accessed our virtual resources; the type of browser and operating system you used; the date, time, and duration of your visit; which specific page you visited, the graphics you viewed and any documents downloaded; the specific links to other sites you accessed from our virtual resources; and the specific links you accessed to our virtual resources from another site.
Additionally, if you access our virtual resources from a mobile phone or other mobile device, the mobile service provider may transmit only identifiable information about the mobile device, which allows us to collect the phone numbers and associate them with the mobile device's identifying information. Some mobile providers also operate systems that indicate the physical location of devices, and we may receive this information if location services are enabled on your device. If you do not want us to use your geolocation information, disable location services in your device settings.

Regardless, we use both automatically collected information and mobile device information to compile general reports about popular pages on our virtual resources and to see how our customers and followers access these virtual resources. We then use that information to manage and improve the virtual resources, make your activities more convenient and efficient, and improve the operation of our virtual resources, for example, by remembering certain information about you to save you time.
We use and retain your personal information in accordance with the laws as long as necessary to carry out the purposes described above in accordance with our internal retention procedures.
The User Should Be Aware of: External Sites, Apps, Links, and Social Networks

We maintain a presence on more than one social media platform, such as Twitter, Facebook, YouTube, and LinkedIn. Additionally, we may allow features of our virtual resources to connect with, or be visible from, that external social media presence. Similarly, our virtual resources may contain links to other websites or apps controlled by third parties.

We are not responsible for the content or privacy policies of social media platforms or any third-party website or application we are linked to. Those apps, sites, and platforms are not controlled by us and therefore have their own privacy policies and terms of use. If you have questions about how those apps, sites, and platforms collect and use personal information, you should read their privacy policies in detail and contact them using the information they provide.
WHEN/WHO WE SHARE PERSONAL INFORMATION WITH

We use non-personal information to manage our virtual resources, improve them, and make business decisions about what programs our customers might like.
We use voluntarily provided personal information for our legitimate interests, including responding to your inquiries and providing the services you have requested, among other uses described below. We do not sell or rent your personal information to third-party information vendors or marketing companies. As you might expect, we only disclose your information when required by law. We may use your personal information when we have your consent to do so, when necessary, or permitted under applicable laws.
Affiliates

In addition to the third parties outlined above, we may share your information, including your personal information, within our family of companies. Those companies will use that information in the same way we do, which includes sending you information about their products, services, or initiatives that may be of interest to you.
Legal Obligation to Disclose Information

We may disclose your information, including your personal information, to government authorities and other third parties when required by government authorities or at our discretion or as required or permitted by law, including, but not limited to, responding to court orders and subpoenas.
Preventing Harm

We may disclose your information, including your personal information, when we have reason to believe that someone is causing harm or interfering with our rights or property, with other users of our virtual resources, or with anyone else who may be harmed by such activities.
Business Transfer

If we or any of our affiliates, or substantially all of their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be one of the transferred assets.
Vendors and Business Partners

We may share your information, including your personal information, with our vendors and other third parties with whom we have contractual relationships. Additionally, we may share your information, including your personal information, with vendors providing software services that you have chosen to assist you with your sales funnels. We do our best to disclose only the information that each of these parties needs.
We have adopted rules for those vendors and business partners who have received personal information from us. We try to bind these vendors and business partners to those rules through written contracts. We attempt to contractually restrict what our vendors and business partners can do with the personal information we provide to them, as it is only used to carry out the business purpose for which it was provided; it is not disclosed to anyone else without our consent or under our instructions; it remains, between us and the relevant vendor or business partner, our property; and it is not transferred outside the United States without our consent.

However, please note that we cannot guarantee that all our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even if they agree, they will always comply.

YOUR RIGHTS AND OPTIONS

You do not have to provide personal information to enjoy most features of our virtual resources. Additionally, you can opt out of certain activities such as newsletters and announcements. Interested parties in certain locations, or whose personal data was obtained while they were in certain locations, may have additional rights under applicable data protection laws.
GDPR Jurisdiction means that countries making up the European Economic Area, the United Kingdom (which will soon leave the European Union), Switzerland, and Japan, having received an "adequacy decision" from the European Commission, adhere to the material terms of the GDPR.
If we are using personal information you have provided to us to send you materials, such as newsletters and product alerts via text messages or email, and you decide you no longer want to receive such material, you can opt-out by following the instructions to do so in the email or other communications (e.g., replying to the text message with "STOP"), or by contacting us using the contact information below. When we receive your request, we will take reasonable steps to remove your name from our distribution list. You should understand that it may take some time to remove your name from our contact lists after your request, and due to this latency, you may continue to receive materials for some time after opting out. In addition to opting out, you have the ability to access, modify, and delete your personal information by contacting us using the information below.
Some browsers have a "do not track" feature that allows you to specify to websites that you do not want your online activities to be tracked. At this time, we do not specifically respond to browser "do not track" signals.

CHILDREN'S PRIVACY

Federal laws impose special restrictions and obligations on operators of websites that direct their operations to, and collect and use information from, children under 13 years of age. We take these requirements very seriously, and considering this, we do not expect our virtual resources to be used by children under 13 years of age without first obtaining verifiable consent from the child's parent or legal guardian. Additionally, we do not knowingly collect personal information from children under 13 years old, only a parent or legal guardian can provide such information after adhering to our verification process to submit such information through the virtual resources. If we notice that any person under 18 years old has entered personal information on our virtual resources without the approval of their parents or legal guardians, and it is not integral to access or use our Services, we will delete the information and will not use it for anything. If you believe a minor under 18 years old has entered personal information on our virtual resources, please contact us at compliance@clickfunnels.com. We encourage parents and legal guardians to talk to their children about the potential risks of providing their personal information on the internet.

HOW WE PROTECT COLLECTED PERSONAL INFORMATION

We will take all security precautions to protect the personal information you have provided us when using our virtual resources. We have adopted a program that includes technical, organizational, administrative, and security measures designed to protect, consistent with accepted industry standards and laws, against anticipated or actual threats to the security of personal information (the "Security Program"). However, we cannot guarantee that your information, whether during its transmission or when stored on our systems, is completely free from unauthorized access, or that loss, misuse, destruction, or alteration will not occur. Except for our duty to maintain the Security Program as required by applicable law, we disclaim any other responsibility for any theft or loss, unauthorized access, damage, or interception of any data or communication, including personal information. We have every reason to believe that our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks threatening the personal information we collect. We also periodically review and update our Security Program as requested by applicable law.

Nevertheless, as part of our Security Program, we have a specific incident response and management procedures that activate whenever we know your personal information may have been compromised. Additionally, we require, as part of our vendor and business partner monitoring procedures, that these parties immediately notify us if they have any reason to believe an incident has occurred that negatively affected the personal information we provided to them.
CALIFORNIA CONSUMER PRIVACY ACT

When we collect personal information from California residents, we are subject to the California Consumer Privacy Act, and those residents have rights under it. This section of our statement is used to allow us to comply with our CCPA obligations and explain your CCPA rights. For the purposes of this section, the words "you" and "your" will refer to California residents.
What We Collect from California Residents

We collect the following categories of personal information: identifiers such as name, address, IP address, and other personal identifiers; personal information described in subdivision (e) of Section 1798.80 (California Customer Records Statute) such as name, address, phone number, credit card number; commercial information such as products or services purchased; internet/electronic activity such as browsing history and search history; geolocation information including geographic coordinates/physical location; and audio, video, electronic, or similar information. We have disclosed these categories of information for business purposes within the past 12 months. We do not sell, nor have we sold within the past 12 months, personal information to third parties.
Rights of California Residents

You have the following rights under the CCPA, in summary disclosure, access, and deletion. You can find more information here. It is important for us that you know that if you exercise these rights, we will not "discriminate" against you by treating you differently from other California residents who use our sites and virtual resources or purchase our services but do not exercise their rights.
You can exercise these rights up to twice every 12 months. To do so, you must contact us at compliance@clickfunnels.com or 1-888-411-0243. We may ask you to fill out a request form. The CCPA only allows us to act on your request if we can verify your identity or authority to make the request, so it will also be necessary to follow our instructions to verify your identity.
If you make a verifiable request considering the above, we will confirm our receipt and respond within the times prescribed by the CCPA.

GENERAL DATA PROTECTION REGULATION

We collect or obtain personal information from data subjects located in the GDPR Jurisdiction. We comply with our GDPR obligations regarding our workforce/applicants, our customers (and their own end customers), and our vendors and business partners through a series of separate notices, contracts, or other terms provided to them at the time, as appropriate, as required by GDPR and local law within each GDPR Jurisdiction.
We describe, in the following section of this statement, how we comply with GDPR for personal information collected from visitors and users of our virtual resources, while they were in a GDPR Jurisdiction. Thus, for the purposes of this section, the words "you" and "your" refer only to visitors and users based in the GDPR Jurisdiction.
What We Collect from You in GDPR Jurisdictions and How We Use It

From you, we collect the categories of personal information that have already been described. The legal basis we rely on for such collection, for its use, and subsequent disclosure is what GDPR refers to as a legitimate interest. As already mentioned in another section of this statement, we do not sell any part of your personal information to third parties, nor do we use it to make automated decisions.
Data Transfer Across States and Third-Party Processor

If we transfer personal information from GDPR Jurisdictions to a location not considered to have adequate privacy protections by the European Commission, we will do what GDPR allows.
Rights of Data Subjects in GDPR Jurisdictions

While we try to allow all our visitors and users of our virtual resources to exercise some degree of control over their personal information, under GDPR we have a legal obligation to do so for you. More specifically, regarding personal information collected from you while you were in a GDPR Jurisdiction, you have these rights: transparency, access, correction and deletion, portability, who, what, and where, and restriction/objection (for more information, click here).
If you want to exercise any of these rights, please contact compliance@clickfunnels.com. Your ability to exercise these rights is subject to certain conditions and exemptions which you can read about in Articles 12 to 23 of the GDPR. Among these conditions is our right to decline part or all of the request if we cannot satisfy our reasonable concerns and doubts about your identity in a way that helps us minimize the risk of an unauthorized person using a GDPR right to access your personal information. We will respond to all requests without delay, considering the timeframes, if any, prescribed by GDPR. If you are not satisfied with how we use your personal information or how we respond to your requests, you have the right to complain to your data protection regulator. The contact information for EU data protection regulators can be found here.

RIGHTS OF DATA SUBJECTS IN OTHER JURISDICTIONS

In other jurisdictions with similar data privacy regulations, we may collect the categories of personal information described. We collect and manage (including disclosure) such information in accordance with applicable local laws. As noted, we do not sell any type of personal information to third parties, nor do we use it for automated decision-making.
CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to change or update this statement at any time. Please periodically review our virtual resources to be aware of such changes, as all collected information is subject to the statement in effect at that time.

CONTACT

If you have questions about our privacy statement or practices, please contact us at:

Etison, LLC
Attn: Legal & Compliance Department
3443 W. Bavaria Street
Eagle, Idaho 83616
compliance@clickfunnels.com

PRIVACY, SECURITY AND TRANSPARENCY STATEMENT
Last version updated on 06/04/2024
Thank you for visiting the virtual resources published by Etison, LLC. Our privacy statement, contained in the following pages, serves to inform you about the type of personal information we collect, how we use it, with whom we share it and why, and what we do to try to protect it. We go into these issues in great detail in the following pages. We encourage you to read them in detail. In the meantime, we'll provide a quick overview below.

What do we collect?
There are two types of information we collect from your online activity, which we then store and use:
non-personal information that is automatically collected from each visitor, such as your device's operating system; and
personal information that you voluntarily provide to us or that is automatically collected.

Why do we use it?
We use non-personal information to manage our online resources, to improve them, and to make business decisions about which programs our customers might like.
We use voluntarily provided personal information to respond to your inquiries and to provide you with the services you have requested, among other uses as described below. We do not sell or rent your information to third party data providers or marketing companies. As you would expect, we will only disclose personal information when required to do so by law.

When do we share it?
We share personal information when necessary to comply with our legal obligations and when we have to comply with contracts we have with our vendors and business partners. We do not sell or rent any personal information to third parties or data brokers, or to marketing companies.

Your Choices and Privacy Rights
You do not have to provide personal information to enjoy most of our online features. In addition, you may opt out of certain activities such as newsletters and advertisements. You may have certain additional rights depending on the jurisdiction in which you reside, or in which your personal data was collected, under applicable data protection.

Contact
Questions about this highlights page or our online privacy statement may be sent to Etison, LLC, ATTN: Legal & Compliance Department, 3443 W. Bavaria Street, Eagle, Idaho 83616 or compliance@clickfunnels.com.
The English version of this privacy statement is the controlling version regardless of any translation you may attempt to make.

Virtual assets are the features of the websites we own that allow you to interact with our websites, as well as applications that we have created and distributed to allow our customers and fans to view our virtual assets or otherwise interact with the content we offer.

FROM WHOM WE COLLECT PERSONAL INFORMATION
We may collect personal information from the following groups of stakeholders: visitors and users of our online and mobile resources; our customers; current members of our workforce and those applying for posted jobs; and third-party vendors and business partners.
Personal information typically refers to information that can be used to identify you or that can be easily linked to you (e.g. your name, address, telephone number, email address, social security number and date of birth). Privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of their consumers or stakeholders that they protect. If those laws apply to us, such as in the case of The California Consumer Privacy Act ("CCPA") or The EU General Data Protection Regulation ("GDPR"), our use of the phrase "personal information" includes the unique elements required by those laws.

Categories of Information We Collect


The categories of information we collect from each of these groups, and how we use it, differ. As you may have noticed, the same person may fall into more than one group. Most of this statement addresses our processing and sharing of personal information collected from visitors and users, and from our virtual resource customers.

However, we collect and retain the types of professional or employee-related personal information that one would expect an employer to have about its current and former workforce, and new job applicants. We provide the legally required collection notices and describe our use and dissemination of personal information of our workforce and applicants in greater detail in internal confidential human resources manuals and documents accessible to our workforce members or published on the proprietary workforce/applicant portals we operate. In some cases, these portals and applications may be managed by third parties who transfer personal information to us. In these situations, the legal responsibility to provide notice rests with the third parties, not us.

Additionally, like any corporate entity, we purchase goods and services, lease equipment and office space, and attend industry events. In doing so, we interact with many existing and potential future vendors and business partners from whom we necessarily collect certain personal information connected with our contractual business relationships. We use and share personal information collected from our vendors and colleagues to manage, administer, and fulfill our contracts with them or share information about our products. We describe our use of vendors' or colleagues' personal information in more detail in the confidential contracts with those parties or in the supplier management portals we operate.
WHAT WE COLLECT

There are two types of information we obtain from your online use, which we then store and use: (i) non-personal information that is automatically saved from each visitor, such as the operating system used by your device; and (ii) personal information that you voluntarily provide to us or that is collected automatically.
By using our virtual resources or purchasing our products or services, you imply that you agree to this section of our privacy statement and that we may use and disclose your information in the manner we have described.
Information Voluntarily Provided

If you participate in certain activities through our online and mobile resources (virtual resources), you may be asked to provide us with information about yourself. The types of personal information we collect in these situations are identifiers (such as your name, email address, address, and phone number), professional information (such as your business affiliation), and financial accounting information (such as your credit card information). We do not sell, rent, or trade voluntarily provided personal information to third parties.

If you do not want us to collect this type of personal information, please do not provide it to us. This means you should not participate in the virtual activities we propose, and it would be more convenient to contact us by phone or mail. Participation is your decision only. Non-participation may limit your ability to fully take advantage of the virtual resources, but it will not affect your ability to access certain information available to the general public regarding the virtual resources.

Some examples of how you might voluntarily provide us with your personal information and how we might use it:

    Emails and Online Forms: When you send us an email or complete an online form, whether to contact us, your email along with other personal information (e.g., your home address or phone number) that may be in the content of your message or attached to it, will be retained by us and used to respond directly to you and process your request. Depending on the personal information provided, communication from us may be through emails, phone calls, and/or text messages. We may also send you information about any of our products or services we think might interest you.

    Registering for an Account: When you register for an account or register your child for a sub-account, you provide us with personal information such as your name and email address (or your child's name and email address), which we will retain. We use that information to create and manage your account and, in some cases, to set up a password and profile to communicate with you and any sub-account you have created via email.

    Registering for Events: When you register for events, conferences, or programs that we may organize ourselves (rather than subcontracting to a third-party event manager with its own privacy policies), you will be providing the types of identifiers we have described earlier. If the event requires a fee, we may request your credit card details or other financial information. We use this information to register you for the event and send you notifications about the same event.

    Subscribing to Our Service: We use any information provided by our customers to fulfill our contractual obligations and provide the products and services they have paid for, to manage their accounts, and communicate with them.

    Social Media and Community Features: Some of our virtual resources may offer community features similar to social networks, allowing users to post messages and comments, and/or upload an image or other files. If you choose to use these features, the information you upload, including your screen name and any other personal information, will be in the public domain and not covered by this statement.

Information Collected Automatically

When you visit our virtual resources, basic information is passively collected through your browser using tracking technologies, such as a "cookie," which is a small text file that is downloaded to your computer or mobile device when you access the virtual resources. It allows us to recognize your computer or mobile device and store some information about your preferences or past actions.

We allow vendors to use cookies or similar technologies to collect information about your browsing activities while you have been using the site. For example, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how you use the virtual resources and improve your experience when you visit the virtual resources. For more information on how Google uses this information, visit www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

The internet activity information collected through cookies and other similar means includes things like: the domain name and IP address from which you accessed our virtual resources; the type of browser and operating system you used; the date, time, and duration of your visit; which specific page you visited, the graphics you viewed and any documents downloaded; the specific links to other sites you accessed from our virtual resources; and the specific links you accessed to our virtual resources from another site.
Additionally, if you access our virtual resources from a mobile phone or other mobile device, the mobile service provider may transmit only identifiable information about the mobile device, which allows us to collect the phone numbers and associate them with the mobile device's identifying information. Some mobile providers also operate systems that indicate the physical location of devices, and we may receive this information if location services are enabled on your device. If you do not want us to use your geolocation information, disable location services in your device settings.

Regardless, we use both automatically collected information and mobile device information to compile general reports about popular pages on our virtual resources and to see how our customers and followers access these virtual resources. We then use that information to manage and improve the virtual resources, make your activities more convenient and efficient, and improve the operation of our virtual resources, for example, by remembering certain information about you to save you time.
We use and retain your personal information in accordance with the laws as long as necessary to carry out the purposes described above in accordance with our internal retention procedures.
The User Should Be Aware of: External Sites, Apps, Links, and Social Networks

We maintain a presence on more than one social media platform, such as Twitter, Facebook, YouTube, and LinkedIn. Additionally, we may allow features of our virtual resources to connect with, or be visible from, that external social media presence. Similarly, our virtual resources may contain links to other websites or apps controlled by third parties.

We are not responsible for the content or privacy policies of social media platforms or any third-party website or application we are linked to. Those apps, sites, and platforms are not controlled by us and therefore have their own privacy policies and terms of use. If you have questions about how those apps, sites, and platforms collect and use personal information, you should read their privacy policies in detail and contact them using the information they provide.
WHEN/WHO WE SHARE PERSONAL INFORMATION WITH

We use non-personal information to manage our virtual resources, improve them, and make business decisions about what programs our customers might like.
We use voluntarily provided personal information for our legitimate interests, including responding to your inquiries and providing the services you have requested, among other uses described below. We do not sell or rent your personal information to third-party information vendors or marketing companies. As you might expect, we only disclose your information when required by law. We may use your personal information when we have your consent to do so, when necessary, or permitted under applicable laws.
Affiliates

In addition to the third parties outlined above, we may share your information, including your personal information, within our family of companies. Those companies will use that information in the same way we do, which includes sending you information about their products, services, or initiatives that may be of interest to you.
Legal Obligation to Disclose Information

We may disclose your information, including your personal information, to government authorities and other third parties when required by government authorities or at our discretion or as required or permitted by law, including, but not limited to, responding to court orders and subpoenas.
Preventing Harm

We may disclose your information, including your personal information, when we have reason to believe that someone is causing harm or interfering with our rights or property, with other users of our virtual resources, or with anyone else who may be harmed by such activities.
Business Transfer

If we or any of our affiliates, or substantially all of their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be one of the transferred assets.
Vendors and Business Partners

We may share your information, including your personal information, with our vendors and other third parties with whom we have contractual relationships. Additionally, we may share your information, including your personal information, with vendors providing software services that you have chosen to assist you with your sales funnels. We do our best to disclose only the information that each of these parties needs.
We have adopted rules for those vendors and business partners who have received personal information from us. We try to bind these vendors and business partners to those rules through written contracts. We attempt to contractually restrict what our vendors and business partners can do with the personal information we provide to them, as it is only used to carry out the business purpose for which it was provided; it is not disclosed to anyone else without our consent or under our instructions; it remains, between us and the relevant vendor or business partner, our property; and it is not transferred outside the United States without our consent.

However, please note that we cannot guarantee that all our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even if they agree, they will always comply.

YOUR RIGHTS AND OPTIONS

You do not have to provide personal information to enjoy most features of our virtual resources. Additionally, you can opt out of certain activities such as newsletters and announcements. Interested parties in certain locations, or whose personal data was obtained while they were in certain locations, may have additional rights under applicable data protection laws.
GDPR Jurisdiction means that countries making up the European Economic Area, the United Kingdom (which will soon leave the European Union), Switzerland, and Japan, having received an "adequacy decision" from the European Commission, adhere to the material terms of the GDPR.
If we are using personal information you have provided to us to send you materials, such as newsletters and product alerts via text messages or email, and you decide you no longer want to receive such material, you can opt-out by following the instructions to do so in the email or other communications (e.g., replying to the text message with "STOP"), or by contacting us using the contact information below. When we receive your request, we will take reasonable steps to remove your name from our distribution list. You should understand that it may take some time to remove your name from our contact lists after your request, and due to this latency, you may continue to receive materials for some time after opting out. In addition to opting out, you have the ability to access, modify, and delete your personal information by contacting us using the information below.
Some browsers have a "do not track" feature that allows you to specify to websites that you do not want your online activities to be tracked. At this time, we do not specifically respond to browser "do not track" signals.

CHILDREN'S PRIVACY

Federal laws impose special restrictions and obligations on operators of websites that direct their operations to, and collect and use information from, children under 13 years of age. We take these requirements very seriously, and considering this, we do not expect our virtual resources to be used by children under 13 years of age without first obtaining verifiable consent from the child's parent or legal guardian. Additionally, we do not knowingly collect personal information from children under 13 years old, only a parent or legal guardian can provide such information after adhering to our verification process to submit such information through the virtual resources. If we notice that any person under 18 years old has entered personal information on our virtual resources without the approval of their parents or legal guardians, and it is not integral to access or use our Services, we will delete the information and will not use it for anything. If you believe a minor under 18 years old has entered personal information on our virtual resources, please contact us at compliance@clickfunnels.com. We encourage parents and legal guardians to talk to their children about the potential risks of providing their personal information on the internet.

HOW WE PROTECT COLLECTED PERSONAL INFORMATION

We will take all security precautions to protect the personal information you have provided us when using our virtual resources. We have adopted a program that includes technical, organizational, administrative, and security measures designed to protect, consistent with accepted industry standards and laws, against anticipated or actual threats to the security of personal information (the "Security Program"). However, we cannot guarantee that your information, whether during its transmission or when stored on our systems, is completely free from unauthorized access, or that loss, misuse, destruction, or alteration will not occur. Except for our duty to maintain the Security Program as required by applicable law, we disclaim any other responsibility for any theft or loss, unauthorized access, damage, or interception of any data or communication, including personal information. We have every reason to believe that our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks threatening the personal information we collect. We also periodically review and update our Security Program as requested by applicable law.

Nevertheless, as part of our Security Program, we have a specific incident response and management procedures that activate whenever we know your personal information may have been compromised. Additionally, we require, as part of our vendor and business partner monitoring procedures, that these parties immediately notify us if they have any reason to believe an incident has occurred that negatively affected the personal information we provided to them.
CALIFORNIA CONSUMER PRIVACY ACT

When we collect personal information from California residents, we are subject to the California Consumer Privacy Act, and those residents have rights under it. This section of our statement is used to allow us to comply with our CCPA obligations and explain your CCPA rights. For the purposes of this section, the words "you" and "your" will refer to California residents.
What We Collect from California Residents

We collect the following categories of personal information: identifiers such as name, address, IP address, and other personal identifiers; personal information described in subdivision (e) of Section 1798.80 (California Customer Records Statute) such as name, address, phone number, credit card number; commercial information such as products or services purchased; internet/electronic activity such as browsing history and search history; geolocation information including geographic coordinates/physical location; and audio, video, electronic, or similar information. We have disclosed these categories of information for business purposes within the past 12 months. We do not sell, nor have we sold within the past 12 months, personal information to third parties.
Rights of California Residents

You have the following rights under the CCPA, in summary disclosure, access, and deletion. You can find more information here. It is important for us that you know that if you exercise these rights, we will not "discriminate" against you by treating you differently from other California residents who use our sites and virtual resources or purchase our services but do not exercise their rights.
You can exercise these rights up to twice every 12 months. To do so, you must contact us at compliance@clickfunnels.com or 1-888-411-0243. We may ask you to fill out a request form. The CCPA only allows us to act on your request if we can verify your identity or authority to make the request, so it will also be necessary to follow our instructions to verify your identity.
If you make a verifiable request considering the above, we will confirm our receipt and respond within the times prescribed by the CCPA.

GENERAL DATA PROTECTION REGULATION

We collect or obtain personal information from data subjects located in the GDPR Jurisdiction. We comply with our GDPR obligations regarding our workforce/applicants, our customers (and their own end customers), and our vendors and business partners through a series of separate notices, contracts, or other terms provided to them at the time, as appropriate, as required by GDPR and local law within each GDPR Jurisdiction.
We describe, in the following section of this statement, how we comply with GDPR for personal information collected from visitors and users of our virtual resources, while they were in a GDPR Jurisdiction. Thus, for the purposes of this section, the words "you" and "your" refer only to visitors and users based in the GDPR Jurisdiction.
What We Collect from You in GDPR Jurisdictions and How We Use It

From you, we collect the categories of personal information that have already been described. The legal basis we rely on for such collection, for its use, and subsequent disclosure is what GDPR refers to as a legitimate interest. As already mentioned in another section of this statement, we do not sell any part of your personal information to third parties, nor do we use it to make automated decisions.
Data Transfer Across States and Third-Party Processor

If we transfer personal information from GDPR Jurisdictions to a location not considered to have adequate privacy protections by the European Commission, we will do what GDPR allows.
Rights of Data Subjects in GDPR Jurisdictions

While we try to allow all our visitors and users of our virtual resources to exercise some degree of control over their personal information, under GDPR we have a legal obligation to do so for you. More specifically, regarding personal information collected from you while you were in a GDPR Jurisdiction, you have these rights: transparency, access, correction and deletion, portability, who, what, and where, and restriction/objection (for more information, click here).
If you want to exercise any of these rights, please contact compliance@clickfunnels.com. Your ability to exercise these rights is subject to certain conditions and exemptions which you can read about in Articles 12 to 23 of the GDPR. Among these conditions is our right to decline part or all of the request if we cannot satisfy our reasonable concerns and doubts about your identity in a way that helps us minimize the risk of an unauthorized person using a GDPR right to access your personal information. We will respond to all requests without delay, considering the timeframes, if any, prescribed by GDPR. If you are not satisfied with how we use your personal information or how we respond to your requests, you have the right to complain to your data protection regulator. The contact information for EU data protection regulators can be found here.

RIGHTS OF DATA SUBJECTS IN OTHER JURISDICTIONS

In other jurisdictions with similar data privacy regulations, we may collect the categories of personal information described. We collect and manage (including disclosure) such information in accordance with applicable local laws. As noted, we do not sell any type of personal information to third parties, nor do we use it for automated decision-making.
CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to change or update this statement at any time. Please periodically review our virtual resources to be aware of such changes, as all collected information is subject to the statement in effect at that time.

CONTACT

If you have questions about our privacy statement or practices, please contact us at:

Etison, LLC
Attn: Legal & Compliance Department
3443 W. Bavaria Street
Eagle, Idaho 83616
compliance@clickfunnels.com

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