Welcome to Choose New Thoughts, LLC’s privacy notice.
Choose New Thoughts, LLC and respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data, tell you about your privacy rights, and how the law protects you when:
- we provide to you our alcohol-free challenges and related service offerings (“Services”);
- you visit our website at www.choosenewthoughts.com (regardless of where you visit it from) (“Site”); and
To help makes things clearer we use the following terms to describe the different categories of individuals whose personal data we may collect:
- Browser: means any person accessing our Site.
- Customer: means an individual who is using the Services.
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process your personal data through your use of the Site and Services, including any data you may provide through the Site and when you are using our Services.
The Site is not intended for children and we do not knowingly collect data relating to children.
Choose New Thoughts, LLC is the controller and responsible for your personal data (collectively referred to as “CNT”, “we”, “us” or “our” in this privacy notice). If you have any questions about this privacy notice, including any requests to exercise your legal rights set out below. You can contact CNT by using the contact details set out below.
- Company Name: Choose New Thoughts, LLC
- Contact Email Address: firstname.lastname@example.org
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on April 5, 2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Site may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, and title.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site and App.
- Profile Data includes your unique account reference number, purchases or orders made by you, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our Site and Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
- Review Data includes your name, email address, and order number; together with any feedback you choose to share unless you decide to leave a review on an anonymous basis.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site or App feature or the number of products that are purchased. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We may collect Special Categories of Personal Data about you, including religious or philosophical beliefs, and information about your health. We collect this data in order to provide the Services to you and provide the best service offering. We shall only collect such information with your explicit consent. You are not obliged to provide us such information, and you may continue to use our Services without providing this information. However, we may not be able to provide the best available service offering without this information.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- apply for our products or Services;
- supply goods and services to us;
- create an account on our Site, App, or otherwise;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback.
- Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as PayPal.
- Contact, Technical, and Usage Data from providers of data capturing services, such as Ontraport.
- Identity and Contact Data from publicly available sources based in the United States.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you as a new Customer||(a) Identity(b) Contact||Performance of a contract with you|
|To process and deliver your order including:(a) Manage payments, fees, and charges(b) Collect and recover money owed to us||(a) Identity(b) Contact(c) Financial(d) Transaction||(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)|
|To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)||(a) Identity(b) Contact(c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT Services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)(b) Necessary to comply with a legal obligation|
|To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical||Necessary for our legitimate interests (to study how Customers use our Services, to develop them, to grow our business, and to inform our marketing strategy)|
|To use data analytics to improve our Site, Services, marketing, Customer relationships, and experiences||(a) Technical(b) Usage||Necessary for our legitimate interests (to define types of customers for our products and Services, to keep our Site updated and relevant, to develop our business, and to inform our marketing strategy)|
|To make suggestions and recommendations to you about Services that may be of interest to you||(a) Identity(b) Contact(c) Technical(d) Usage(e) Profile(f) Marketing and Communications||Necessary for our legitimate interests (to develop our Services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you and send them to you through our marketing messages.
You will receive marketing messages from us if you have requested information from us or purchased Services from us and you have not opted out of receiving that marketing.
You have the right to opt-out of receiving marketing communications from us, or third parties, at any time, by:
- informing us that you wish to change your marketing preferences by contacting our customer support team at email@example.com;
- making use of the simple “Email Preferences” link in emails or the “STOP” number for texts; and/or
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a Service purchase, warranty registration, Service experience, or other transactions.
When you interact with the Site, we try to make that experience simple and meaningful. When you visit our Site, our web server sends a cookie to your computer or mobile device (as the case may be). Cookies are small pieces of information that are issued to your computer or device when you visit a website or access or use a mobile application and which store and sometimes track information about your use of the Site. A number of cookies we use last only for the duration of your Site session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer.
Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.
Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Service providers based within and outside the United States who provide IT and system administration, payment, and data capturing services, Ontraport, Google Analytics, and Facebook.
- Professional advisers including lawyers, bankers, auditors, and insurers based within the United States who provide consultancy, banking, legal, insurance, and accounting services.
- Regulators and other authorities based in the United States who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third-party suppliers are based outside the United States. Their processing of your personal data will involve a transfer of data outside the United States.
Whenever we transfer your personal data out of the United States, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield.
- Where we use service providers in the EU or other countries, we may transfer data to them if they are part of the Privacy Shield or we may use specific contracts approved by the European Commission which give personal data similar protections as Privacy Shield.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
What you can do to help protect your data
You should always be cautious when sharing your personal data. No one from our company will ever ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from Choose New Thoughts asking you to do so, please ignore it and do not respond.
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety:
When creating a password, use a difficult word/number combination of at least 8 characters and something that is not easily guessed or something that cannot be easily obtained such as your name, email address, or other personal data that can be easily obtained.
Frequently change your password (you can do this in your account settings.
Avoid using the same password for different online accounts.
How long will you use my personal data?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Access to information: You have the right to request a copy of the information CNT holds about you.
- Ensuring accuracy of information: CNT wants to make sure that your personal information is accurate and up-to-date. You may ask CNT to correct or complete information that is inaccurate or incomplete.
- Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require CNT to delete personal information held about you.
- Ability to restrict processing: You may also have the right to require CNT to restrict CNT’s use of your personal information in certain circumstances. This may apply, for example, where you have notified CNT that the information CNT holds about you is incorrect and you would like CNT to stop using such information until CNT has verified that it is accurate.
- Right to data portability: You may have the right to receive personal data CNT holds about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
- Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body.
- Preventing direct marketing: CNT does not sell your personal data. From time to time, CNT may send emails containing information about new features and other news about us. This is considered direct marketing. CNT will always inform you if CNT intends to use your personal data or if CNT intends to disclose your information to any third party for such purposes.
- Objecting to other uses of your information: You may also have the right to object to CNT’s use of your information in other circumstances. In particular, where you have consented to CNT’s use of your personal data, you have the right to withdraw such consent at any time.
If you would like further information on how you can exercise these rights, please email us at email@example.com
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We will try to respond to all legitimate requests within 30 days. Occasionally this timeframe may be extended up to 60 days depending on the complexity of your request, or the number of requests that you have made. In this case, we will notify you and keep you updated.