Privacy Policy

Effective June _, 2018

IPS Mastermind, LLC (“IPS Mastermind”, “we”, or “us”) recognizes the importance of privacy.

Please read this privacy policy (“Policy”) carefully as it contains important information on who we

are, how and why we collect, store, use, and share personal information, your rights in relation

to your personal information and on how to contact us and supervisory authorities if you have a

complaint. This Policy addresses:

 Who we are

 How we collect personal information

 What personal information we collect

 How we use your personal information

 With whom we share your personal information

 Legal basis for processing your personal information

 Users outside the United States

 Security and storage of information

 Your legal rights and choices

 Third party links

 Cookies and other tracking mechanisms

 California disclosures

 Changes to the policy

 How to contact us

1. What Personal Information We Collect

The term “personal information” is defined as information that you voluntarily provide us which

personally identified you and/or your contact information, including but not limited to your name,

phone number, email address, and mailing address.

We may process and collect the following personal information when you provide it to us:

 personal name

 email address

 mailing address

 IP address

 username

 date of birth

 debit or credit card information

2. How We Collect Personal Information

Your personal information is collected in various ways:

 directly (e.g. when you complete a form or sign a contract);

 automatically (e.g. when you access our website, or social account); and

 through third parties and publicly available sources (e.g. through Facebook, LinkedIn,

your company website, or otherwise).

3. How We Use Your Personal Information

We use your personal information to:

 renew memberships

 contact you for customer service

 advertise and market products or services

4. With Whom We Share Your Personal Information

We do not share your information with any third parties. We do, however, use the following data

processors who share your personal information with us:

 Thinkific

 Stripe

 PayPal

 Braintree

 ConvertKit

We will share personal information with law enforcement or other authorities if required by law.

We will not share your personal information with any other third party.

5. Legal Basis for Processing Your Personal Information

We rely on these legal grounds to process your personal information:

 Consent. We may use your personal information as described in this Policy subject to

your consent. To withdraw your consent, please contact us at

[email protected]. You may also choose not to provide, or to withdraw, your

consent for cookies. Please see Your Legal Rights and Choices below for more

information on opt-outs.

 Performance of a contract. We may need to collect and use your personal information

to perform our contractual obligations.

 Legitimate Interests. We may use your personal information for our legitimate interests

to provide our services and to improve our services and content. We process information

on behalf of our customers who have legitimate interests in operating their businesses.

We may use technical information as described in this Policy and use personal

information for our advertising and marketing purposes consistent with our legitimate

interests and any choices that we offer or consents that may be required under applicable

law.

6. Users Outside the USA

Countries outside of the European Economic Area (EEA) do not always offer the same levels of

protection to your personal data, so European law has prohibited transfers of personal data

outside of the EEA unless the transfer meets certain criteria.

Many of our third-party service providers are based outside the European Economic Area (EEA)

so their processing of your personal data will involve a transfer of data outside the EEA

Whenever we transfer your personal information out of the EEA, we do our best to ensure a

similar data security by ensuring at least one of these safeguards is in place:

 We will only transfer your personal information to countries that the European

Commission have approved as providing an adequate level of protection for personal

information; or

 Where we use certain service providers, we may use specific contracts or codes of

conduct or certification mechanisms approved by the European Commission which give

personal information the same protection it has in Europe; or

 If we use US-based providers that are part of EU-US Privacy Shield, we may transfer

data to them, as they have equivalent safeguards in place.

If none of the above safeguards are available, we may request your explicit consent to the

specific transfer. You may withdraw this consent.

7. Security and Storage of Information

We have tried to help protect the personal information we collect. Unfortunately, no measures

can be guaranteed to provide 100% security. We cannot guarantee the security of your

personal information in all circumstances.

Take steps to protect against unauthorized access to your device and account by choosing a

robust password nobody else knows or can easily guess and keeping your log-in and password

private. We are not responsible for any lost, stolen, or compromised passwords or for any

activity on your account via unauthorized password activity.

We retain the personal data we collect for so long as reasonably necessary to fulfill the

purposes for which the data was collected, to perform our contractual and legal obligations, and

for any statute of limitations periods to bring and defend claims.

8. Your Legal Rights and Choices

Under the General Data Protection Regulation, you have several important rights free of charge.

In summary, these rights include:

 Fair processing of information and transparency over how we use your use personal

information

 Access to your personal information and to certain other supplementary information that

this Policy is already designed to address

 Correcting any mistakes in your personal information

 Requiring the erasure of personal information about you in certain situations

 Receiving the personal information about you which you have provided to us, in a

structured, commonly used and machine-readable format and may transmit those data to

a third party in certain situations

 Objecting to processing of personal information about you for direct marketing

 Objecting to decisions being taken by automated means which produce legal effects

about you or similarly affect you

 Objecting in certain other situations to our continued processing of your personal

information

 Restricting our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply,

see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights

under the General Data Protection Regulation.

If you would like to exercise any of these rights, please:

 Email, call, or write to us at [email protected]

 Let us have enough information to identify you (e.g., account number, user name,

registration details)

 Let us have proof of your identity and address

 Let us know the information to which your request relates, including any account or

reference numbers, if you have them

If you would like to unsubscribe from any email newsletter, you may click on the unsubscribe

button at the bottom of the email newsletter. The un-subscription processing may take a few

days.

9. Third-Party Links

This website 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

policies. When you leave our website, we encourage you to read the privacy policy of every

website you visit.

10. Cookies and Other Tracking Mechanisms

You can set your browser to refuse all or some browser cookies, or to alert you when websites

set or access cookies. If you disable or refuse cookies, some parts of this website may become

inaccessible or not function properly.

11. Children

IPS Mastermind is not directed to children under thirteen (13) years of age. We do not

knowingly collect personal information from children under 13. If we discover that a child under

13 has provided us with personal information, we will promptly delete that information from our

systems.

12. California Disclosures

 California Information-Sharing Disclosure. California residents may request a list of all

third parties regarding which we have disclosed any information about you for direct

marketing purposes and the categories of information disclosed. If you are a California

resident and want such a list, please send us a written request by email to

[email protected] with “California Privacy Rights” in the subject line.

 Do Not Track. We do not currently recognize or respond to browser-initiated Do Not

Track signals as there is no consistent industry standard for compliance.

13. Changes to The Policy

This Policy is current as of the Effective Date above. We may change this Policy occasionally,

and if we do we will post any changes, including any material changes, on this page, so please

check back periodically. If you continue to use our service after those changes are in effect, you

agree to the revised Policy.

14. Contact Us

Please contact us at [email protected] if you have questions about this Policy.