Introduction

Your privacy is critically important to Arete Information Services, LLC just as it is to you.  Please read this privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information (PII) and other information linked to your personal identity (personal data) and how we respond to your rights in regard to it. This policy and the site implementation have been designed to comply with the European Union General Data Protection Regulation (GDPR). Although that regulation is only legally enforceable for persons physically present in European Union Member States we have decided to provide the same protections for all users of UFearless regardless of where they might be. We believe that this is the right thing to do even though we are not obligated to do it.

In this policy the company will be referred to as “we”, “us”, or the “company”. The web site (www.ufearless.net or ufearless.net) will be referred to as “UFearless”, “the web site“. or “the site“. UFearless includes the UFearless.Net Learning Center (UFNLC) learning environment which is located at https://ufearless.net/learning/center/. You will be referred to as “you” or the “user“. This Privacy Policy will be referred to as the “Privacy Policy”.

This Privacy Policy lets you know what information we collect from you, how we make use of that information, and what legal base we have for the processing of each type of information. It points out to you your rights in regard to the collection, processing, transfer, and storage of your personal information. In this policy “personal information” and “personal data” mean the same thing.

Access to UFearless implies the your full consent, understanding, and compliance without any reservations to its Terms of Use. It also implies that you have read and understood this Privacy Policy and the Cookie Policy. You are not permitted to use the site if these conditions are not met.

As defined by the GDPR we are both a data controller and a data processor. We do not meet the conditions requiring the assignment of a Data Protection Officer (DPO). However, any concerns that you might otherwise direct to a DPO can be directed to the contact point given below.

When we refer to any one thing or list of things as an example we mean that what is given as the example is illustrative of the concept but does not necessarily constitute an exhaustive list of everything that might be applicable.

Who Are We?

The UFearless is an Internet property of Arete Information Services, LLC. Arete Information Services LLC is an Internet services company that develops and operates several Internet services including web sites and on line learning sites.

If you have any questions please contact us:

Email: contact@areteinformationservices.com

Phone: 919-827-1182

Postal mailing address:

Arete Information Services, LLC
500 Westover Dr #10821
Sanford, NC 27330

Changes to This Policy

From time to time updates will be made to this policy. Because your acknowledgement of understanding of the Privacy Policy is required for you to use UFearless we will ask you to provide a fresh acknowledgement whenever it changes in a significant way. If we have your email we will send you an email to inform you of the change. We will also attempt to identify your access to UFearless through the UFearless ID Cookie (see the Cookie Policy for more info). If we detect that you have accessed UFearless and have a stale acknowledgement on record a pop up will ask for a new one. Your acknowledgement will be recorded in our database so we do not have ask you for it every time you visit the site. A list of changes will be maintained below linked to a description of what was changed.

Changes to the policy are never retroactive. We will provide the date that each change becomes effective.

Privacy Policy Change Log:

  • 18 Jun 2018: Initial policy version created and published.

What Personal Information Is Collected and How Is It Collected?

When registering, signing up for a newsletter, ordering goods or services, or performing other actions on UFearless, as appropriate, you may be asked to enter elements of personal information. The following categories of personal information may be collected although not all elements will necessarily be collected in all cases depending on the actions taken by you on UFearless.

We collect information from both visitors and users. By visitors we mean those who access the site without directly identifying themselves such as just going to the site and browsing its content. By users we mean those who establish an account on the site and identify themselves by logging in to that account when they access it.

Personal Information Which Might Be Solicited From the User on the Website:

There is personal information that you enter into the web site when you interact with it. This information is entered through forms, check boxes, radio buttons, text fields, and other standard elements of web pages that permit the entry of information. For details about what is collected and under what legal base click here.

Personal Information You Freely Provide Without Solicitation

Some information is freely provided by you without our soliciting it from you. We will not ask for your consent to use this information because its legal base for processing is our legitimate interest. However, you do have the right to object to our collection and use of it. If you wish to object you can get more information here. For more information about what information is collected on this basis and how it is used click here.

Personal Information Collected Automatically by the System

Some information that can have a connection to your personal identity is collected automatically by the web system itself. We will not ask for your consent to use this information because its legal base for processing is our legitimate interest. However, you do have the right to object to our collection and use of it. If you wish to object you can get more information here. For more information about what information is collected on this basis and how it is used click here.

Personal Information Collected Automatically Through Instrumentation of the Web Site

Some information is collected by using instrumentation to detect actions that you take as you move around in the web site. By instrumentation we mean the placement of detection code at critical points in the web site so that they can collect specific events have occurred. We will not ask for your consent to use this information because its legal base for processing is our legitimate interest. However, you do have the right to object to our collection and use of it. If you wish to object you can get more information here. For more information about what information is collected on this basis and how it is used click here.

Personal Information Collected Through UFearless by a Third Party

When you purchase anything directly through the UFearless site the payment processor will normally collect payment information from you. UFearless normally does not collect or store that information although it might not be apparent to you that it is a third party collecting it. For more information about what information is collected on this basis and how it is used click here.

Personal Information We Collect From Third Parties

With the single exception of information received back from a payment processor when you make a purchase directly on the site we do not collect any personal information about you from third parties. For example we do not access any information about from Google, Facebook, or other sources of your personal information.

We are doing the best we can to avoid your getting third-party cookies also. You will note that we do not have any of those convenient sharing icons. That is because those icons drop third-part cookies when you share something using them.

How Do We Use the Information We Collect?

The ways in which we use your personal information are directly linked to the legal base for processing. The legal bases which apply to our processing are: consent, legitimate interest, performance of a contract, and legal obligation.

Consent

We must have your consent to collect and process any personal information that does not fall under any of the other legal bases for processing defined by the GDPR. We use this information primarily to communicate with you via email and to personalize our communications with you so that what we send is the best possible match to your interests and needs. This includes communications about the site and its services, alerts to situations that could affect you, requests for you to participate in a site activity such as a survey, and to send you information about products and services offered for sale.

Legitimate Interest

We will use your personal information where necessary for purposes which are in our, or third parties, legitimate interests. This utilization centers primarily around site operation and security, legal obligations, prevention of fraud, site improvement, and direct marketing. For more details on how we use information collected under legitimate interest click here.

Performance of a Contract

We will use your personal information to fulfill a contract or to take the necessary steps toward establishing a contract. This will be primarily to execute a purchase by you on the site, to enroll you into a UFNLC course, or to provide any other service on the site that requires a contractual relationship. When we are soliciting personal information for establishment or execution of a contract we will indicate that to you in the process.

Legal Obligation

Under certain circumstances we have a legal obligation to provide your personal information to law enforcement or other government authorities. We do not have any obligation to have your consent to do this. This typically occurs in circumstances of investigation of a crime.

When and to Whom Do We Disclose Your Personal Information?

We only disclose your personal information to a third party in a very limited set of circumstances. The only one that occurs frequently and for most users the only one ever during their use of UFearless is to execute a contractual obligation in processing a payment with a third party payment processor. For more details on when and to whom we might disclose your personal information click here.

What About Storage and Transfer of Your Personal Information?

UFearless is based in the United States of America. Your personal information is stored and processed in the USA. Any transfer outside of the USA would only occur in the case of a legal obligation as indicated in the section above. In normal circumstances there is no transfer of your information outside of the USA.

How Do We Keep Your Personal Information Secure?

Your personal information is stored and processed on servers that are protected by modern information security methods and practices. Unique security mechanisms and procedures have been implemented to improve the safety of your information as required by the GDPR. The UFearless system is monitored and tested regularly by a Certified Information Systems Security Professional (CISSP).

To learn more about how we keep your personal information secure click here.

What Control Do You Have Over Your Personal Information?

The GDPR ensures that you have a great deal of control over how your personal data is collected, stored, transferred, and processed. The following are categories of control offered to you by UFearless:

Revocation of Consent to Processing of Personal Information

If you have previously given consent to us to use specific personal information for a specific purpose you have the right to revoke that consent at any time. If you revoke your consent we will immediately cease to process that information for that purpose. For more detailed information about your right to revocation of consent click here.

Right to Object to Collection and Processing of Personal Information

In regard to any personal information that we process under the legal base of our legitimate interests you have the right to object to that processing. If you submit an objection we will cease to perform the corresponding processing unless we are doing it under obligation of keeping the site safe or due to legal obligations. For more information about your right to object click here.

Right to Access Personal Information We Have About You

You have the right to access and obtain a copy of the personal information that we have about you. If you request your data a CSV standard format file will be made available to you that contains all the personal data we have about you at the time of the request. For more information about how to access your personal information click here.

Right to Deletion of Personal Information and Right To Be Forgotten

You have the right to have personal data about yourself deleted from the site or, if desired, to be completely forgotten by the site. Being forgotten means that all personal data about you will be deleted along with any accounts you might have and everything will return to a state almost as if you had never visited the site. For more information about your right to have data deleted or to be completely forgotten click here.

Right to Correction of Incorrect Personal Information

You have the right to request correction or modification of personal information that we have about you. For more information about your right to correct incorrect data click here.

Right to Lodge a Complaint

If you are physically present in the European Union you have the right to lodge a complaint against the site if you think we have violated your rights. You should contact us and give us the opportunity to resolve the problem before you do that, however. You would need to lodge your complaint with the Supervisory Authority in the country where you reside. Although not an official listing the following article provides contact information for each country: GDPR Data Protection Supervisory Authority Listing.

Our Use of Cookies and Other Tracking Technologies

We use cookies as a tracking technology that allows us recognize you when you return to the site from a previous visit. We also use them as an integrated part of the system which makes it possible for you to navigate from page to page within the site and maintain your identity. For a full explanation of our use of cookies please see the Cookie Policy.

What About Children?

We do not intentionally collect personal information on people below the age of 16. If you are below the age of 16 you are not allowed to use the site and we ask that you not do so. We ask for confirmation of minimum age upon initial visit to the site and assume that you have answered truthfully since we have no way to check your actual age.

How Long Will Your Personal Information Be Kept?

We keep your personal information for as long as necessary to provide our services to you and to comply with our legal obligations.

California Online Privacy Protection Act

UFearless is compliant with the California Online Privacy Protection Act (CalOPPA). In a nutshell this means that web sites that hold PII on California consumers must post a privacy policy which is labeled as such and easy to find, must allow users to visit anonymously, must provide notification of changes to the privacy policy, and must allow users to change their personal information. For more information about our CalOPPA compliance click here.

How does the Website handle Do Not Track (DNT) signals?

In a nutshell: We don’t honor DNT signals. To learn more about why that is click here.

COPPA (Children Online Privacy Protection Act)

UFearless is compliant with the Children Online Privacy Protection Act (COPPA). We do not market to or collect personal information of children under 13 years of age. To learn more about our COPPA compliance click here.

Fair Information Practices

UFearless specifically agrees to the breach notification and Individual Redress Principle of the Fair Information Practices Principles. To learn more about our compliance click here.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules in the United States for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To learn more about our CAN-SPAM Act compliance click here.