PRIVACY POLICY

This Privacy Policy applies to all online courses, virtual workshops, and podcasts (“Programs”) offered by Tragedy and Hope, Inc., creators/owners of the AUTONOMY course (DBA AUTONOMY), a Connecticut S-Corp (“AUTONOMY”, “we” or “us”) on our website at GetAUTONOMY.info (the “Website”).  By accessing the Website, purchasing, or downloading any Program, or otherwise signifying your acceptance of this Privacy Policy, you agree to this Privacy Policy on your own behalf and on behalf of any other person or company listed on the order, registration, signup or similar form for such Program. 

What This Privacy Policy Covers

• This policy covers how Tragedy and Hope, Inc. (DBA AUTONOMY) treats personal data that AUTONOMY collects and receives, including information related to any products, services, or Programs available on this Website. Personal data is defined as information about you that is personally identifiable, such as your name, mailing address, email address, or other contact information, and that is not otherwise publicly available.
• This policy does not apply to the practices of advertisers or other companies that AUTONOMY does not own or control or to people that AUTONOMY does not employ or manage.
• References to "data" in this Privacy Policy will refer to whatever data you use within AUTONOMY’s products, services, or Programs to collect and or process, whether it is data collected in a form, data inserted on a site hosted by AUTONOMY, or data acquired on your behalf from sources internal or external to your organization.
• “Personal data” is defined as information about you that is personally identifiable, such as your name, mailing address, email address, or other contact information, and that is not otherwise publicly available.
• This policy does not apply to non-personal information − data in a form that does not permit direct association with any specific individual. AUTONOMY may collect, use, transfer, and disclose non-personal information for any lawful purpose.
• This Privacy Policy is effective on July 1, 2023 or the date upon which you enter into an agreement for one or more of AUTONOMY’s products, services or Programs, whichever is later.

Information Collection, Use and Retention

• You can generally visit the Website without revealing any personal information about yourself.
• AUTONOMY collects personal information (including but not limited to your name, e-mail address and certain financial information collected at kajabi.com)when you sign up, log in, fill out order forms at https://getautonomy.info/ participate in a “blueprint strategy call,” or by purchasing or downloading any of AUTONOMY’s other Programs or educational materials.
• When you click on such links, AUTONOMY asks for information such as your name, email address, telephone number, and zip code. Once you click on such links and become a customer of AUTONOMY, you are not anonymous to AUTONOMY.
• In the course of communicating with you after your initial registration, AUTONOMY collects information about your personal situation, goals, work history, resume, skills, other information you would include in a resume or Linked-In® profile, and your transactions with AUTONOMY and with some of our business partners and affiliates, including information about your use of the products and services that we offer.   We do not collect medical information or “sensitive personal data” (as such quoted term is defined for purposes of GDPR) such as your race, religion, sex or sexual orientation.
• AUTONOMY may automatically receive and record information on our server logs from your browser, including your IP address, AUTONOMY cookie information, and the page you request.

• When you visit the Website, AUTONOMY collects usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Website and Programs ("usage information"). AUTONOMY uses tracking technologies (including cookies (including cookies stored in HTML-5), web beacons/GIFs, embedded scripts, e-tags/cache browsers) to collect usage information.
• AUTONOMY may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.
• AUTONOMY may collect additional information from you if you access the Website or any Programs through a mobile device (e.g., your unique device identifier, device’s operating system, mobile carrier, general location or your location).

• AUTONOMY uses information for the following general purposes: to customize the website, advertising and content; to fulfill your requests for products, services and Programs; to improve the Programs and customer relations; to contact you; to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms and Conditions; and to conduct research.

AUTONOMY retains the information we collect from and about you for as long as it is necessary and relevant for the Website’s operations, and in accordance with applicable legal requirements. You consent to AUTONOMY’s retention of your video viewing tracking data for as long as permissible under applicable law — up to one (1) year after you close your account or otherwise withdraw consent for video tracking.

Minors

The Website is a general audience site or service and it is not intended for children under the age of 13. AUTONOMY does not knowingly collect "personal information" (as defined by the United States Children's Online Privacy Protection Act or "COPPA") on the Website, and does not knowingly collect any personal information from children younger than the age of thirteen (13) as required by U.S. law. AUTONOMY will delete any personal information collected that is later determined to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to AUTONOMY, please contact us via email at [email protected].

Legal Basis For Processing (European Union, Switzerland and United Kingdom Visitors Only)

References to “GDPR” in this Privacy Policy refer to the General Data Protection Regulation adopted by the Parliament of the European Union and published as Regulation (EU) 2016/679 (General Data Protection Regulation), which became effective on May 25, 2018.  The full text of the GDPR in English can be viewed at https://gdpr-info.eu/.

• If you are a visitor from the European Union (EU), Switzerland or the United Kingdom, our legal basis for collecting and processing the information described above will depend on the information concerned and the specific context in which we collect and process it. We collect and process information from you only where we have your consent (Art. 6 para 1 lit. a) GDPR), where we need the information to provide our contractual obligation to you (Art. 6 para 1 lit. b) GDPR) or where we have a legitimate interest to do so.
• If you wish to learn more about specific legal ground(s) we rely on to process your information for any particular purpose (including any legitimate interests we have to process information), then please contact us using the details provided below under “Contacting Us”. By way of example, we rely on our legitimate interests to process information for fraud prevention and detection, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms (Art. 6 para 1 lit. f) GDPR).

Information Sharing and Disclosure

• AUTONOMY does not sell, rent, or share personal information about users or minors who respond to questions, play games or otherwise engage with our products and services with other people or nonaffiliated companies except to provide our Programs and other products and services, when we have your permission, and under the following circumstances:

• We provide the information to trusted partners and affiliates who work on behalf of or with AUTONOMY or have been granted the right to access our customer data. These companies may use your personal information to help AUTONOMY communicate with you about offers from AUTONOMY and our marketing partners and affiliates. These companies do not have any independent right to share this information but have the right to use the information in accordance with their individual privacy policies.
• We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or to defend against legal claims;
• We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or as otherwise required by law;
• AUTONOMY may display targeted advertisements based on personal information. Advertisers (including ad serving companies) may assume that people who interact with, view, or click on targeted ads meet the targeting criteria.
• We may aggregate data collected from use of AUTONOMY’s products, services and Programs and publish, disseminate, disclose and otherwise use such data as non-personal information -- data in a form that does not permit direct association with any specific individual – for any lawful purpose.
• We may consolidate your e-mail address and any other personal information included in our e-mail customer and membership lists with similar e-mail lists maintained by Autonomy Limited, its subsidiaries and affiliates.
• We will transfer information about you to our successors and assigns if AUTONOMY is acquired by or merged with another company, or if AUTONOMY sells all or substantially all of its assets to another company, or if a controlling interest in AUTONOMY is transferred or sold to another company. In this event, AUTONOMY will notify you before more information about you is transferred and becomes subject to a different privacy policy.

Information Shared Publicly

User Content and Public Information. The Service may permit you to share or otherwise submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, information about your location, questions, comments, suggestions or other content including personal information (collectively, "User Content"). We or others permissioned by us may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including personal information, in connection with your User Content. Please note that AUTONOMY does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Service or what others do with information you share with them on the Service. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Service.

Name and Likeness.  We may also publish your name, voice, likeness and other personal information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Service, please review our Service's Terms and Conditions.

User Testimonials.  We often receive testimonials and comments from users who have had positive experiences with our products and services. We occasionally publish such content. When we publish this content, we may identify our users by their social media account usernames and publish their social media account profile pictures.

Cookies

• AUTONOMY may use cookies and other tracking technologies (for instance from Google, Facebook and LinkedIn, etc.) to keep, and sometimes track, information about you on our website. Cookies are small data files that are sent to your browser from a web server and stored on your computer’s hard drive. Cookies track where you travel on the website and what you view. In doing so, a cookie may enable us to relate your use of our online services to your Personal Information.
• AUTONOMY may let other companies that show advertisements on some of our pages set and access their cookies on your computer. Other companies’ use of their cookies is subject to their own privacy policies, not this one. Advertisers or other companies do not have access to AUTONOMY’s cookies.
• We use information gathered from these tracking technologies so that we can analyze trends, administer the website, track users’ movements around the website, improve our products, services and applications, and gather demographic information about our customer base as a whole. We may combine information we obtain through tracking technologies with other Personal Information that we have collected about you in order to make our Products, communications and advertisements more targeted to your interests.
• Please note that the website is not presently configured to respond to DNT or “do not track” signals from web browsers or mobile devices. As such, AUTONOMY does not recognize or respond to Do Not Track requests.
• When visiting the AUTONOMY website, you will see a “pop-up” message informing you that “our website uses cookies to improve your experience. By continuing to use our site, you accept the use of cookies and our Privacy Policy.  If you reject cookies, you may continue to visit the website and use any services available on the website, but some areas of the website may be limited.

Confidentiality and Security

• We limit access to personal information about you to employees or service providers who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.
• We have physical, electronic and procedural safeguards to protect personal information about you.
• In certain areas AUTONOMY uses industry-standard SSL-encryption to protect sensitive data transmissions.
• AUTONOMY encourages our marketing partners to use SSH and SCP (secure Telnet and FTP) programs in order to better safeguard customer data.

International Transfers

• AUTONOMY operates its services from servers located in the United States and the information it collects through clients is processed solely in the United States. Laws governing the collection and use of data in the United States may not be equivalent to those in the country where you reside, but AUTONOMY will at all times protect your data in accordance with this Privacy Policy.
• We and/or our selected third-party partners may also collect data about visitors’ activities on this Website and across the Internet over time for non-advertising purposes, including to conduct analytics, measure trends, and streamline website usability. The technologies used for this purpose may include log files, cookies, web beacons, and social media plug-ins. One of the service providers we may use is Google Analytics. To learn more about how Google Analytics collects and processes data and the choices you may have to control these activities, you may visit https://www.google.com/policies/privacy/.
• AUTONOMY may share your information with our affiliates and other third parties described above who are based in countries outside of your country of residence. While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take all reasonable measures to protect your information in accordance with this Privacy Policy and all applicable legal requirements.

Sensitive Personal Data

▪   We do not knowingly collect or obtain from third parties, any personal data, including any “Sensitive Personal Data,” as defined under the GDPR. “Sensitive Personal Data” are personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data.

Your Rights

• You have the right to access the information that AUTONOMY maintains about you, request deletion of your data, update your data, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information and you correct or amend that information if it is inaccurate or has been processed in violation of privacy laws, to the extent allowed by law, including the GDPR.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to opt-out from our marketing communications at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “Contacting Us” heading below.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

To exercise these rights, please email [email protected] (include “privacy” in the subject line of your message).

Rights of Users in the United Kingdom, Switzerland and the European Union

AUTONOMY operates its technology from servers located in the United States and the information it collects through clients is processed solely in the United States. Laws governing the collection and use of data in the United States may not be equivalent to those in the country where you reside, but AUTONOMY will at all times protect your data in accordance with this Privacy Policy.

In order to provide our products, services, Programs and other educational and instructional materials to you, we must transfer your data to the United States and process it there. If you are using the services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries.

Rights of Users in Certain U.S. States

This Supplemental Notice applies solely to residents of the States of California, Virginia, Colorado, Connecticut, and Utah who have interacted with us in the ways described in the introduction of this Privacy Policy, and who have certain privacy rights under the applicable laws in their state (respectively, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act (collectively, “Certain State Privacy Laws”)

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We do not collect any “sensitive personal information” as defined under Certain State Privacy laws. The length of time we retain this information is generally twelve months.  In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from users of our website when the user or their agent provides personal information to us.
• Indirectly from you.  For example, by observing your interactions on our website and by using cookies.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: Personal Information categories.

Category D: Commercial Information

Category F: Internet or other similar network activity.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes other than those set forth in our Privacy Notice without providing you notice.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our Affiliates.
• Service providers and business partners.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information of consumers collected from the Website as defined by Certain State Privacy Laws.

We have shared personal information with our Affiliates and service providers as disclosed above.

Your Rights and Choices

Certain State Privacy Laws provide their residents with specific rights regarding their personal information. This section describes your rights if you are a resident subject to the Certain State Privacy Laws and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• The categories of personal information sold, the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; and
• The categories of personal information disclosed for a business purpose.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Opt-Out Request Rights

You have the right to opt-out of the sharing of your personal information that we collected from you. Once we receive and confirm your verifiable consumer request to delete your personal information, we will delete (and direct our service providers to delete) your personal information from our records and stop sharing it, unless an exception applies. 

Right to Request Correction of Inaccurate Information

You have the right to request correction of inaccurate information.  Once we receive and confirm your verifiable consumer request, we will correct any inaccurate information identified in the request our records, unless an exception applies.

Right to Appeal

If you are a Virginia, Colorado or Connecticut resident and we were unable to fulfill your request, we will notify you. You may appeal our decision by emailing us at [e-mail address of client] within fourteen calendar days, including “Appeal Request” in the subject line, with a detailed reason for your appeal, as well as your state of residence. If you are dissatisfied with our decision on your appeal, you may contact your applicable state Attorney General:

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

• Calling toll free at [toll-free telephone number of company] or by submitting a request to [e-mail address of company].
• Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request, to process and fulfill the request, and for necessary record keeping.

Process Used to Verify an Access and/or Deletion Request

You will be required to submit 4 pieces of information including your name, address, email, and phone number. We will use this information to search our systems and determine if we have information about you. If we are able to locate information about you, we will fulfill your access and/or deletion request. If we are not able to match all 4 pieces of information you submit, we may provide you with a report that includes the categories of personal information we collect, use, disclose, and sell.

Response Timing and Format

We try to respond to a verifiable consumer request within 45 days of its receipt, unless a shorter time period applies under Certain State Privacy Laws.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under Certain State Privacy Laws.

Changes to this Privacy Policy

• AUTONOMY may update this policy. We will notify you about significant changes in the way we treat personal information by posting a notice to our website at https://getautonomy.info/ or, at our option, by sending a notice to the primary email address we have on file for you.

Contacting Us

If you have questions or suggestions, please email [email protected]

Last Updated/Effective Date:  February 5, 2024