Privacy Policy
Last Updated and Effective: July 27, 2024
What is this document?
Privacy policies can often be complex and difficult to understand. We have endeavored to make our Privacy Policy easy to comprehend and navigate. If you encounter any queries while going through it, please feel free to contact us at hello@musicteacherguild.com.
In this Policy, unless specified otherwise, "data" encompasses information tied to an individual or household, such as name, email address, phone number, device ID, third-party identifiers, contact information, and communications with Consultants via our digital communication platform (the "Platform") for rendering services ("Consultants"). In certain circumstances, some jurisdictions may classify this as "personal data," "personally identifiable information," or "sensitive personal data." By using our app or website, you acknowledge and consent to both the Terms and Conditions and this Privacy Policy, including our sharing of specific data with Service Providers.
Though the Sovereign+, LLC management seeks to comply with legal requirements and to build trust with our membership, you may have to work directly with these third-party companies in addition to us when it comes to your data. We have attempted to be inclusive and thorough in this document but take no legal responsibility for the Terms of Service, Privacy Policies, or other policies enacted or enforced by these third-party services.
Will this document be updated?
If there are significant updates to this Privacy Policy, we will inform you through our website or app when you log into your account. Please check this page regularly for the most recent updates.
How to navigate this document:
This document is broken into seven sections divided by topic. To navigate to a section, reference the list below, which provides examples of the types of questions that will be answered in that section.
SECTION 1 - Data Collection and Processing
What data do we collect, store, and Process?
Why do we collect and Process this data?
SECTION 2 - Data Sharing
Why do we share your data?
How do you use my data to comply with the law?
Do we sell your data?
Do we share any information with third-party advertisers between you and your Consultant?
SECTION 3 - Data Retention, Erasure, and Exporting
How long do we retain your data?
What type of data do we retain and why?
How can you request data erasure or a copy of your data?
Why must we retain your data to comply with the law?
SECTION 4 - Security and Anonymity
How do we keep your data secure?
How do you best remain anonymous when using Sovereign+, LLC?
Who can see the conversations with your Consultant?
SECTION 5 - Cookies and Web Beacons
What is a cookie or web beacon?
What do we use them for?
How can you opt-in / opt out of them?
SECTION 6 - Additional privacy notices for California, UK, GDPR, and non-US/UK/EU residents
SECTION 1
Data Collection and Processing
Do you collect, store, or Process my data?
The types of data we handle are outlined below. We manage this data to facilitate the operation of the Platform and ensure your effective use of our services. This may involve sending periodic emails or text messages, sometimes related to service provision and other times for marketing purposes. You have the option to opt out of receiving texts or marketing communications at any point. Moreover, with your consent, we may handle and disclose specific data to Third Parties for advertising objectives. Further information can be found in the pertinent sections of this Policy.
What specific data are you Processing and why do you collect it?
The data we process varies based on your utilization of our website, app, or Platform. We delineate the particular data we gather and process in the subsequent section, along with the business rationale for its collection and processing in the following section.
Information regarding the duration for which we retain the data we collect and process within these categories can be found in the "How long do you retain my data and how do I request data erasure?" section of this Privacy Policy.
Visitor Data
What is Collected:
Data collected includes details such as the specific pages visited or features engaged with when you access the website, app, or Platform, along with the duration of your visit, any site/app/Platform errors encountered, information regarding the type of device and browser utilized, and your IP address. If available based on your device settings, we may process your Third Party identifier or advertising ID, and if you opt into Advertising (formerly known as "Targeting cookies") and web beacons, this information will be shared with Third Parties.
What it is Used for:
The primary purposes for which your data is utilized include:
1. Connecting you with consulting services: Ensuring you are matched with suitable consulting services that meet your needs.
2. Facilitating tools for you and your Consultant: Providing tools and resources to enhance communication and collaboration between you and your Consultant.
3. Communicating with you: Engaging in effective communication to address queries, provide updates, and offer support.
4. Monitoring and improving consulting quality: Continuously assessing and enhancing the quality of consulting services provided to you.
5. Personalizing your web or app experience: Tailoring your online experience to align with your preferences and interests.
6. Helping us understand how you use our services: Analyzing usage patterns to improve the effectiveness and convenience of our products and services, as well as to introduce new features.
7. Complying with laws: Adhering to legal obligations and regulations governing the provision of consulting services.
8. Protecting your safety and the safety of others: Ensuring the safety and well-being of both users and practitioners involved in consulting sessions.
9. Sending you opportunities, promotions, news, updates, and reminders: Keeping you informed about relevant opportunities, promotions, news updates, and reminders related to our services and your account.
Onboarding Data
What is Collected:
When registering an account on the Platform, users begin by completing a questionnaire. The information provided in this questionnaire is processed by us to finalize the account creation process.
What it is Used for:
The primary purposes for which your onboarding data is utilized include:
Connecting users with consulting services.
Monitoring and enhancing the quality of consulting.
Personalizing the user experience on the web or app.
Analyzing user behavior to improve service effectiveness, and convenience, and introduce new features.
Complying with legal requirements.
Sending users opportunities, promotions, news, updates, and reminders regarding services and their accounts.
Account Data
What is Collected:
After a user creates an account with the Platform, we proceed to process various types of data. This includes the account name chosen by the user, along with additional demographic and contact details such as email address, age, phone number, emergency contact information, and whether the user verifies their email address.
What it is Used for:
Enabling consulting tools for both you and your Consultant.
Tailoring your experience on the web or app.
Assisting us in comprehending your service usage, refining our offerings for enhanced effectiveness and convenience, and introducing new features.
Adhering to legal obligations.
Safeguarding your safety and that of others.
User ID
What is Collected:
Every user, including Consultants, who register an account with us is allocated a sequentially-generated user ID. These IDs are distinct for each account and are essential for the proper functioning of the Platform.
What it is Used for:
Facilitating connections with consulting services.
Enabling consulting tools for both you and your Consultant.
Engaging in effective communication with you.
Monitoring and enhancing the quality of consulting.
Personalizing your experience on the web or app.
Analyzing service usage to enhance effectiveness, and convenience, and introduce new features.
Adhering to legal requirements.
Ensuring your safety and that of others.
Sending opportunities, promotions, news updates, and reminders regarding services and your account.
Transaction Data
What is Collected:
We handle data to facilitate payment transactions conducted on the Platform. This includes information on whether a user has successfully completed payment for our services, signed up for services through a trial offer, canceled or concluded a trial, received discounts or financial aid, or obtained any extensions or refunds. Additionally, we process data regarding whether a visitor has registered to create an account.
What it is Used for:
Connecting you with consulting services
Facilitating consulting tools for you and your Consultant
Communicating with you
Monitoring and improving consulting quality
Personalizing your web or app experience
Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
Complying with laws
Protecting your safety and the safety of others
Sending you opportunities, promotions, news, updates, and reminders about our services and your account
Member Engagement Data
What is Collected:
We collect data for Platform login and associated activities, including user login instances, timing of logins, and activity metrics such as the quantity and duration of messages exchanged, timing of messages, scheduling and duration of live sessions, and usage patterns of other features like worksheets, journals, and goals. Notably, this category excludes consulting data such as the content of messages, live sessions, journal entries, worksheets, or goals.
What it is Used for:
Enabling consulting tools for both you and your Consultant
Engaging in communication with you
Observing and enhancing the quality of consulting
Customizing your web or app interaction
Assisting us in comprehending your service usage, refining our offerings for improved effectiveness and convenience, and introducing new features
Adhering to legal requirements
Ensuring your safety and that of others
Delivering opportunities, promotions, news updates, and reminders regarding our services and your account
Consulting Data
What is Collected:
We handle written communications and associated data that users share with their Consultants to facilitate the consulting process. This encompasses messages exchanged with Consultants, worksheets, and journal entries. Additionally, users have the option to send audio messages, which are transcribed automatically. It's important to note that we do not record video or audio sessions with Consultants.
What it is Used for:
Facilitating consulting tools for you and your Consultant
Complying with laws
Consulting Quality Data
What is Collected:
We manage client feedback concerning their Consultant, which includes ratings and reviews provided by clients, as well as any actions taken regarding switching Consultants or discontinuing consulting, along with the reasons selected by the client. Additionally, we handle data related to Consultant session availability, session cancellations, and instances of clients not attending scheduled sessions.
What it is Used for:
Enabling connection to consulting services
Facilitating consulting tools for both you and your Consultant
Engaging in communication with you
Observing and enhancing the quality of consulting
Tailoring your web or app experience
Assisting in understanding service usage for improvement and introducing new features
Sending opportunities, promotions, news updates, and reminders regarding services and your account
Customer Service and Communication Data
What is Collected:
We Process communications users have with Customer Service.
What it is Used for:
Communicating with you
Complying with laws
Protecting your safety and the safety of others
Consultant Data
What is Collected:
To ensure seamless management of music educators applying to be Consultants on our platform, including assessing, matching, credentialing, re-credentialing, conducting checks, issuing payment, and providing necessary tax documentation, we collect pertinent information. This includes the educator's name, banking details, gender, date of birth, relevant governmental identification numbers (such as SSN/FEIN), email address, phone number, physical address, licensing details, as well as their areas of expertise, educational background, and work history. Additionally, Consultants may opt, outside the scope of this Policy, to consent to facial scans to facilitate logins and identity verification.
What it is Used for:
Connecting you with consulting services
Facilitating consulting tools for you and your Consultant
Communicating with you
Personalizing your web or app experience
Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
Complying with laws
Protecting your safety and the safety of others
Sending you opportunities, promotions, news, updates and reminders about our services and your account
Consultant Engagement Data
What is Collected:
For Consultants, we process data including the frequency and timing of logins to the Platform, the number of live or asynchronous sessions conducted, the number of messages and words exchanged, the number of shared documents, and the count of assignments or journal entries received.
What it is Used for:
Connecting you with consulting services
Facilitating consulting tools for you and your Consultant
If you’re a Consultant on our Platform, or being recruited to join us, in addition to the above, we may Process Consultant Data, consulting Quality Data, Consultant Engagement Data, User ID, Onboarding Data, Account Registration Data to:
Assist in the Consultant recruitment process and onboard you to the Platform;
Operate the Platform, match clients to you based on your preferences, and facilitate the communication between you and your clients;
Verify your identity and secure your account;
Run background checks and other screening required for credentialing and re-credentialing purposes;
To pay you and comply with all relevant tax laws;
Provide you quality statistics, feedback from our Sovereign+, LLC Operations team, and feedback from clients.
Offer you information about new features, opportunities, perks, and other incentives.
Promote your profile on Sovereign+, LLC and with third-party websites and directories to get you more clients (to opt-out email elisa@elisajanson.com).
Send you emails, calls, or SMS reminders, notifications & updates about your application, profile, or account.
In addition to processing, we also share some data with Service Providers in order for us to operate the Platform and to perform necessary website and application functions. Additionally, when you opt into sharing, we share certain data with Third Parties.
Do you Process location data?
We utilize your IP address to approximate your location, allowing us to personalize the platform accordingly. This includes displaying relevant information about our services tailored to visitors from your country, enhancing your user experience. For instance, we may auto-populate your state and country fields during onboarding questionnaires. However, we do not request or process exact location data obtained through GPS on your phone.
Additionally, when you provide address information for your emergency contact details upon starting consulting on the Platform, we process this data to comply with regulatory requirements and ethical standards. This information may be used by your Consultant in situations of immediate concern for your safety. When filling out this field, we may also utilize your rough location to offer autocomplete suggestions for convenience.
Moreover, rough location data obtained through your IP address is utilized by the ReCAPTCHA security API tool we employ. ReCAPTCHA assists in identifying potential threats attempting to access our site, thereby enhancing security measures. You can find further details on ReCAPTCHA's Privacy Policy and Terms of Service via the provided links.
SECTION 2
Data Sharing
What are the purposes for sharing my data?
Purposes for Sharing Your Data:
1. Compliance with Applicable Laws:
- Your data may be shared to comply with legal requirements, such as responding to subpoenas. Your chosen Consultant typically decides on producing consulting notes or messages, but it's advisable to discuss any concerns with them regarding disclosure obligations.
2. Support Services:
- Occasionally, your data may be accessed by select employees of our parent company for support services, such as handling legal correspondence.
3. Service Providers:
- We may share certain data with Service Providers who assist in operating the Platform, including:
- Data hosting and storage providers, e.g., Amazon Web Services (AWS).
- Technology Service Providers to enhance Platform functionality.
- Customer Service Providers to manage Member inquiries securely.
- Email management and communication Service Providers for easier communication.
- Billing and payment processing Service Providers like Stripe for secure transactions and payments to Consultants.
- Reporting and analytics Service Providers to track site usage.
- Advisors and lawyers for business matters.
4. Platform Safety and Security:
- Some of your data may be shared with Service Providers to ensure Platform and user safety.
5. Consultant Recruitment:
- If you're a Consultant or being recruited, certain data may be shared with Consultant recruiters to facilitate the recruitment process.
6. Group-level Usage Data:
- For Members receiving services through an organization, group-level usage data may be shared with the organization.
7. Asset Sale, Merger, or Bankruptcy:
- Your data may be shared in connection with an asset sale, merger, or bankruptcy.
8. Public Information:
- Information made publicly available on the Platform may be seen and used by anyone.
9. Analytics and Advertising:
- If you opt in to "Analytics" or "Advertising," data may be processed for activities like analyzing traffic sources or sharing activity data for advertising purposes.
Please refer to the relevant sections for more information on data usage and privacy preferences.
How do you use my data to comply with the law?
If the law says we have to, we'll work with government groups. This isn't just something we do at Sovereign+, LLC, but it's also what happens with in-person consulting. For example, if a court asks for some information, like with a subpoena, we have to give it to them. Usually, we let your Consultant decide whether or not to share any notes or messages you've talked about together. Different places have strict rules about how Consultants and clients should keep things private. It's a good idea to talk to your Consultant early on if you're worried about what they might have to tell others.
Also, Consultants might have to tell the authorities about certain things because of their role. Some laws say they have to share information or do something if: (a) someone has been hurt or might be in danger; (b) someone is thinking about hurting themselves a lot; (c) someone might hurt someone else; or (d) a court says they have to get official treatment. If you're worried about this, you should talk to your mental healthcare provider and Consultant about it.
Do you sell my data?
We don't receive payment from anyone for any data. However, in California, the laws define "sale" broadly, which includes sharing personal information in exchange for anything valuable. If you choose to allow us to use Advertising cookies and web beacons, this action might be seen as a "sale" of personal information under California law. For more details about your data rights as a California resident, please refer to the additional notice for California residents.
Are you using my data for advertising?
To connect with individuals seeking consulting, clinics, feedback, or support, we advertise on certain third-party web platforms like websites and apps. Our aim is to provide ads that are relevant, interesting, and personalized to minimize advertising costs and subsequent expenses for you.
If you agree to the use of Advertising cookies and web beacons, some of your information, such as your IP address, third-party identifier (if applicable), hashed User ID (if applicable), and certain Visitor Data, excluding activity while logged in and engaged in consulting, may be shared for advertising purposes. Consequently, you might encounter ads for our services on selected third-party websites.
It's important to note that we do not engage in "retargeting" advertising, which involves showing you ads based on your previous site visits or actions. Additionally, we do not share any data you share with your Consultant with third-party advertisers. Even if you opt in to Advertising cookies and web beacons, we do not disclose any private information, including Member names, email addresses, phone numbers, diagnosis, questionnaire responses, session details, journal entries, messages, or worksheets.
For further details about Third Parties with whom Sovereign+, LLC may share data, please refer to our Third Party Partners Disclosure List.
SECTION 3
Data Retention, Erasure, and Exporting
How long do you retain my data and how do I request data erasure?
Sovereign+, LLC is dedicated to ensuring that all relevant Member data is kept only for the necessary duration required to offer appropriate products and services, and in line with applicable legal obligations.
Certain types of data are retained for a period following the cancellation or inactivity of your Membership. This retention allows for smooth reactivation if you choose to use our services again and enables Consultants to access historical information. Keeping this data is also essential for the functionality of our products and services.
Apart from the data retention schedule detailed below, Sovereign+, LLC has a procedure in place for all Members, regardless of their location, to promptly handle requests for data erasure or access.
The following sections outline both the expected duration for retaining Member data based on specific account information and the process for requesting data erasure and access. In this Policy, data erasure refers to the permanent removal or obscuring of identifiable data (See "What is this Privacy Policy") to ensure it is no longer accessible by anyone.
Retention Policy
Sovereign+, LLC’s data retention policies are based upon what data is being Processed1, whether or not the Member has participated in consulting, and if the Member proactively requested data erasure or if the erasure is triggered due to Platform inactivity.
I am a Member who...
How long your data is retained
Did not start consulting
Did not request data erasure
Your data is retained for 3 years after your last login date and is then erased.
Did start consulting
Did not request data erasure
Your data is retained for 10 years after your last login date and is then erased.
Did not start consulting
Did request data erasure
Your data is erased within 24 hours of the erasure request.
Did start consulting
Did request data erasure
Communications (e.g. record of Member complaints or deletion requests), or disclosures of PII to Third Parties2 is erased after 10 years.
All other personal identifiable information in the following categories is erased within 24 hours of the erasure request: Visitor Data; Onboarding Data; Account Data; User ID; Transaction Data; Member Engagement Data; consulting Data; Customer Service and Communications Data.
Data Protection Rights:
As mentioned, you have specific rights under data protection laws, including the right to ask us to delete personal data we have about you, and the right to request a copy of it. The following sections explain how you can make use of these rights.
Requesting Data Erasure:
To request data erasure, please email elisa@elisajanson.com. You will receive a confirmation email from us within 24 hours of your request. We will only comply with a request for the erasure of your data if we can verify your identity. There is usually no charge. In exceptional circumstances, we may charge a reasonable fee after discussing the fee with you. We have specific requirements that must be met in order for us to process your data erasure request.
Requirements:
Only you or your authorized representative may make a request on your behalf. You may also make a request on behalf of your minor child depending on the applicable laws.
You must provide sufficient information that allows us to reasonably verify your identity or status as an authorized representative.
You must provide details that allow us to understand, evaluate, and respond to your request.
In some circumstances, legal or regulatory requirements limit our ability to honor erasure requests. As such, we may decline requests for erasure if the information is:
Subject to a litigation hold or legal request to preserve it.
Necessary to comply with laws and regulations and to maintain business integrity.
Additionally, compliance obligations require us to retain records documenting certain interactions you have with us related to your Membership. As such, we cannot honor erasure requests for information contained in records of:
Communications about complaints and erasure or access requests.
Disclosures of personal data to Third Parties.
If we don’t intend to comply with a request, then we will tell you why this is the case, and outline how we weighed your rights and freedoms against our legal obligations. In such instances, any information retained will only be used for purposes contemplated under the legally recognized exemption.
Requesting a copy of personal data
Data which we maintain includes email interactions with our help desk, which is stored on your email system. You may also request this information by writing to elisa@elisajanson.com. As with data erasure, we are not always able to respect your request for data access. For more information on why this may be and how the situation will be handled, please reference the previous section.
SECTION 4
Security and Anonymity
How do you keep my data secure?
We apply industry standards and strive to apply best practices to prevent any unauthorized access and disclosure. Internet-based services carry inherent security risks, but our systems infrastructure, encryption technology, operation and processes are all designed, built, and maintained with your security and privacy in mind.
We adhere to industry standards and strive to implement best practices to prevent any unauthorized access and disclosure. While internet-based services inherently pose security risks, our systems infrastructure, encryption technology, operations, and processes are all constructed, developed, and maintained with your security and privacy as top priorities.
Utilizing modern best practices in browsing encryption (SSL).
Implementing robust monitoring and alerting systems and procedures, which encompass both automated systems and human oversight. Our 24/7 security rotation ensures constant vigilance.
For your own security, please bear in mind the following:
Phishing: Be cautious of online identity theft or account hacking attempts, known as phishing. We will never ask for your login or credit card information through non-secure or unsolicited communication. Always exercise diligence when providing account information and ensure it's within our secure system.
External Links: Our Platform may include links to external websites or services. We do not oversee external websites and do not control their privacy policies or terms of use. The presence of a link to a website does not signify an endorsement, authorization, or affiliation with that external party or its privacy and security policies or practices.
Can I sign up for Sovereign+, LLC and remain anonymous?
Even though we try to limit the kinds of information you must provide to us as discussed above, it is very difficult to be truly “anonymous” when you use any app or the internet. If you’re interested in further limiting what data is Processed, email elisa@elisajanson.com to opt-out of tracking via cookies or web beacons, or for instructions on how to remove previously set cookies.
Who can see the interactions I have with my Consultant?
You and your Consultant are able to see the messages you send and the documents, audio, or video you submit. If you consent, a Consultant who is employed as part of the Sovereign+, LLC Operations Team may review correspondence with your Consultant for quality assurance purposes. For example, if you raise a concern about your Consultant, or if we have concerns about a specific Consultant’s abilities or ethics.
Messages with your Consultant are not shared with any third party, and your live sessions are not recorded. We also do not share when you send a message, or have a session with your Consultant, with any Third Party.
How do you treat data from children?
We don’t knowingly collect or solicit any data or information from anyone under the age of thirteen (13) or knowingly allow such persons to become our users. The Platform is not directed at and not intended to be used by children under the age of thirteen (13). If you’re aware that we have collected personal information from a child under age of thirteen (13), please let us know by contacting us, and we’ll delete that information.
SECTION 5
Cookies and Web Beacons
What is a cookie or web beacon?
A "cookie" is a small data file stored within a computer's folder, used for record-keeping purposes. Cookies are employed to improve the Platform's performance, customize your experience, and may also be utilized for Third Party tracking, as explained earlier. For instance, cookies might enable you to swiftly log into specific platforms and websites without repeatedly entering your credentials.
A "web beacon" or "pixel" refers to a minuscule, sometimes invisible image or embedded code inserted on a web page or email, capable of reporting your visit or usage to a Third Party, as mentioned earlier. Generally, these tools are employed to monitor user activity for purposes such as web analytics, advertising optimization, or page tagging.
What are you using cookies and web beacons for?
We use our own, Service Providers and Third Party cookies and web beacons to deliver a faster and safer experience, to monitor and analyze usage, to comply with laws, and for advertising purposes. To read more about the kinds of third-party cookies we use and their purposes, to update your settings, or to opt out, email elisa@elisajanson.com.
How do I opt out of cookies, web beacons, and other tracking technology?
Please visit our third-party hosting platform’s Privacy Policy to opt-out of tracking via cookies or web beacons, or for instructions on how to remove previously set cookies.
How can I stop receiving direct marketing emails from you?
You can always opt out of receiving marketing emails. In order to opt out, you can select the unsubscribe link located at the bottom of the relevant email communication.
SECTION 6
Additional privacy notices for California, UK, GDPR, and non-US/UK/EU residents
Additional Privacy Notice for California Residents
This Privacy Notice for California Residents supplements the Sovereign+, LLC Privacy Policy to comply with the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act ("CPRA") of 2020.
The CCPA and the CPRA are California laws that provide its residents with certain rights over information about them, including notice about the categories of personal information we have collected from them in the preceding twelve (12) months and the purposes for which the information is used or disclosed, and correction of personal information.
The data referenced in this document may fall in certain defined categories under the CCPA and CPRA. Accordingly, we may have collected:
Identifiers;
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
Protected classification characteristics under California or federal law;
Commercial information;
Biometric information;
Internet or other similar network activity;
Geolocation data;
Sensory data;
Sensitive Personal Information;
Professional or employment-related information; and
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
The information that we may have shared in the past 12 months falls into the following personal information categories under the CCPA and CPRA:
Identifiers;
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
Protected classification characteristics under California or federal law;
Commercial information;
Internet or other similar network activity;
Geolocation data;
Sensory data;
Sensitive Personal Information; and
Professional or employment-related information;
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
As noted in the Section titled “Do you sell my data?”, our “sale” of information (including sale of information about consumers under the age of 16) consists of the disclosure of your information for targeted advertising purposes, and we aren’t paid by any external or Third Party2 for any data. The information that we may have “sold” (for purposes of the CCPA and CPRA) in the past 12 months falls into the following personal information categories under the CCPA and CPRA:
Identifiers;
Commercial information; and
Internet or other similar network activity.
Do I have the right to know what information you have about me?
Yes, as a California resident, you can request certain information about what we have Processed over the past 12 months. Once we receive and verify your consumer request, we can provide:
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 that personal information.
The categories of Third Parties with whom we shared that personal information.
The specific pieces of personal information we collected about you.
Whether we disclose your personal information for a business purpose and the personal information categories that each category of recipient obtained.
We will verify your identity by matching the information you provide with information we maintain about you or via biometrics (specifically, FaceID via iOS). You also have the right to request that we correct personal information about you if it is found to be inaccurate. To make such a request, please email elisa@elisajanson.com.
Can I “opt out” or request that you delete my information?
Yes, you can request that we delete your data as described in the section of this Policy called: "How do I request my data or delete it?" Once your request is received and verified by matching the information you provide with information that we maintain about you or via biometrics, we’ll move forward with the Process of deleting your information in line with our legal requirements and Retention Policy. We cannot fulfill a deletion request and need to retain your information if the data is necessary to:
Provide you services, take actions reasonably anticipated within the context of our ongoing business relationship, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
Comply with applicable laws, including but not limited to the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) and information covered by the California Confidentiality of Medical Information Act.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
As noted above, you do not need to opt into the “sale” of personal information about you by withdrawing your consent to accept cookies used for advertising. Our websites are also designed to implement a do-not-sell privacy preference.
Other California privacy rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to Third Parties for direct marketing purposes. To make such a request, please send an email to DPO@Sovereign+, LLC.com.
General Data Protection Regulation (GDPR) and UK General Data Protection Regulation Notice
This section provides additional information about our Policy relevant to you if you are from the European Economic Area (the EEA), United Kingdom, and Switzerland (together “European Area Countries”). It supplements and should be read in conjunction with the rest of the Policy. Under the European Area Countries’ privacy laws, we are the Controller with respect to your data.
When is my data used?
When it is in our legitimate interests or an external third party’s legitimate interests (“legitimate interest” is a term defined by the General Data Protection Regulation (GDPR) and UK General Data Protection Regulation Notice). Our legitimate interests in this instance include managing the Platform and Sovereign+, LLC’s business, safety and security of the infrastructure, prevention of fraud, research and development, and management of contracts and legal claims.
When it is needed for the provision of the Platform. In particular, for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Platform. We only rely on our or an external third party’s legitimate interests to Process your data when these interests are not overridden by your rights and interests.
When it is necessary to do so to comply with any legal obligations imposed upon us under our contractual obligations or our contractual obligation or applicable law.
In rare instances, when it is a medical emergency, we may use your data to protect your or another’s vital interests if consent is not a reasonable option.
When you have consented to the use of your data, for marketing purposes or through the use of cookies and web beacons. Where consent is the legal basis, you have the right to withdraw your consent at any time.
What Lawful Basis for Sensitive Data is Used in the UK and EEA?
Sovereign+, LLC may also collect and Process certain categories of personal information, which may be considered “sensitive personal information” in the UK and EEA. The lawful basis for this Processing are (1) health and social care, (2) our establishment, exercise, or defense of a right or legal obligation, (3) substantial public interest, and (4) consent. Where consent is the legal basis, you have the right to withdraw your consent at any time. Sensitive personal information that we Process includes your racial or ethnic origin, religious or philosophical beliefs, and data concerning your health or about your sex life or sexual orientation.
When you begin to use our services and register your account, we ask you to provide answers to a questionnaire to customize the service, to match you with a Consultant, and to provide consulting and related services to you. In providing your responses to the questionnaire, you may provide us with “sensitive personal Information” as described above. You may also continue to share such data with us as you receive services. This data is necessary as it allows us to continue providing services to you and customize our services for you. It is also necessary to provide healthcare with a personalized and well-selected Consultant based on points of data that impact your consulting and educational needs. The Consultant also reviews this data and can choose not to work with you if they are not a good fit. We may also use this information to improve our service and understand how you interact with the services.
How we obtain your personal information
Sovereign+, LLC obtains the categories of personal information listed above from the following sources:
Directly from you, such as information when you apply to be a counselor or that you submit during the Process of using and paying for our Services.
Indirectly from you, such as through your actions on our website.
From external business partners, such as social media sites, ad networks, and analytics providers.
What are my rights and choices under European Area Countries' laws?
European Area Country residents have specific rights regarding their data. This section describes your rights if you reside in the European Area Countries and explains how to exercise those rights.
Subject access request: You may be entitled to ask us for a copy of any data that we hold. We will normally send you a copy within one month of your request. However, that period may be extended by two additional months, taking into account the complexity of the request or the difficulty in accessing the data you request. There is usually no charge. In exceptional circumstances, we may charge a reasonable fee after discussing the fee with you.
Right to rectification: If the data we hold about you is inaccurate, you may request rectification. The data will be checked, and, where appropriate, inaccuracies will be rectified.
Right to erasure: In certain circumstances, you may be entitled to ask us to erase your data.
Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic data we hold about you to another organization.
Right to object: You may object to your data being used for direct marketing. You may object to the continued use of your data when we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for Processing your data, you may object to us continuing to Process your data. Still, you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling, legitimate grounds for us to continue to Process your data, we may continue to do so. In that event, we will let you know the reasons for our decision. Objecting to certain Processing may sometimes impact our ability to provide you with services.
Rights related to automated decision-making including profiling: We use limited data to operate the Platform and to carry out certain profiling activities to support and grow our business. When doing so, we rely upon our legitimate interests as the lawful basis for Processing your data, and you may exercise the above rights if you do not wish us to Process your data in this way.
To exercise the rights in relation to your data set out in this section, please contact us at elisa@elisajanson.com.
Is my data transferred internationally?
As a part of our standard business practices, we may transfer your data to organizations based in countries that have not been granted an adequacy decision under the General Data Protection Regulation. Where data is transferred to such countries, we shall ensure that specific safeguards or derogations have been established.
These might include where the data transfer is necessary in order to fulfill a contract between us and yourself, where we have received your specific consent after having made you aware of any risks involved, or where contracts are in place between us and the Third-Parties involved that ensure the recipient organization has a suitable standard of data protection in place.
Additional Privacy Notice for non-US, non-UK, and non-EU residents
As a part of our standard business practices, data is transferred outside of many visitors’ countries of residence and predominantly used, accessed and processed within the U.S. Fortunately, given the robust and rigorous nature of privacy laws in the US, UK, and EU with which we comply, Sovereign+, LLC considers that this has the effect of protecting user information in a way that, overall, is at least substantially similar or in many ways exceeds non-US data privacy legal requirements. To the extent we contract with vendors who are outside of the U.S, we ensure that specific safeguards have been established to protect that data.