Privacy Policy
Updated as of August 6, 2024
The purpose of this Privacy Policy is to explain the privacy practices of BellHarr, LLC DBA Two Gens Tri (“we” or “us”) in connection with the following products and services (collectively, the “Services”): (i) this website (www.twogenstri.com) (as updated and modified, the “Website”); (ii) any software applications made available by us for use on or through computer and mobile devices; (iii) any educational programs, classes, courses, workshops, worksheets, training materials, guidebooks and other similar related content and materials that we provide (collectively, and as updated and modified, each a “Program”); (iv) any other digital communications or content that we may publish that link to this Privacy Policy, including any content or advertisements that we may place on third-party websites (e.g., Facebook); (v) any new features, updates or modifications of any of the foregoing; and (vi) any other services that we provide you in connection with any of the foregoing, including your participation in any of our membership programs. Please remember, however, that this Privacy Policy only governs our own practices. If you are interacting with any Services through any third-party website, application or other service, their own privacy policies will govern. We recommend you review the privacy policies of these third parties. By accessing or using the Services, you are agreeing to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Services or provide us with any of your Personal Information (defined below).
All references to “you” or “your” in this Privacy Policy mean the person who accesses or uses the Services in any manner, and each of your heirs, assigns, and successors. If you use the Services on behalf of an entity, organization, or company, you represent and warrant that you have the authority to bind that entity to this Privacy Policy.
Please also visit our Terms & Conditions, which will govern the terms that will apply to your use of the Services, including if you wish to enforce any of your rights – https://www.twogenstri.com/terms. By accessing or using the Services, you are also agreeing to our Terms & Conditions.
Types of Information We Collect and Use
Our Services may collect, use, store and transfer different kinds of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you as a particular consumer or device (“Personal Information”), such as:
- Identity Data includes your name, date of birth, gender, unique personal identifiers or numbers, signature, physical characteristics or description, employment, or other similar information.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Transaction Data includes details about payments, products and services you have purchased, or other purchasing or consuming histories or preferences, bank account number, credit card number, debit card number, or any other financial information.
- Technical Data includes internet protocol (IP) addresses, your browser type and version, time zone setting and location, geolocation, cookies, carrier information, browser plug-in types and versions, operating system and platform, sensory data (e.g., audio, electronic, visual, or similar information), or other technology on the devices you use to access the Services.
- Profile Data includes your username, password, preferences, settings, login and profile information, feedback, and survey responses.
- Usage Data includes information about how you use the Services, such as the session duration, pages served, the source of the request, and the preceding page views.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, and the materials that you have viewed and interacted with.
We also may collect, use, and share “Aggregated Data” such as statistical or demographic data. Aggregated Data could be derived from your Personal Information but is not considered Personal Information as this data will not directly or indirectly reveal your identity. We may collect, retain, use and share Aggregate Data in any manner without restriction. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, citizenship, medical condition, physical or mental disability, marital status, religious or philosophical beliefs, veteran or military status, sexual orientation, political opinions, criminal history, information about your health, and genetic and biometric data).
How do we Collect Personal Information?
Submitted by You: We collect Personal Information you provide to us, for example if you:
- Contact us with a question, comment, or request
- Initiate a search on the Website or use any of the Services
- Complete a transaction on our Website or using the Services
- Respond to any promotional and/or other marketing offers, including any promotional offers initiated by us or third-party marketing automation providers
- Participate in any membership or subscription program
- Respond to any survey or leave any feedback
- Submit any other content, such as on our social media pages
Cookies and Similar Automatic Tracking Technology: The Services may use cookies, flash cookies, web beacons, embedded scripts, location-identifying technology or similar technology to collect Personal Information automatically as you use the Services. These technologies also allow us to collect or interact with Personal Information stored on your device or browser and monitor your usage of the Services. We may also engage third-party companies to help us collect and track this data (for example Google Analytics). You may be able to deactivate or opt-out of some of these technologies through your browser settings, device settings, or take other steps, depending on the methods you use to access the Services. For more information, please click here to read the Network of Advertising Initiative’s recommendations for Opting Out of Internet Advertisements. Please note that disabling cookies or deleting information contained in cookies or flash cookies may interfere with the performance and features of the Services, including not being able to store your preferences or login information. (Your browser settings may also allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.)
IP Addresses: An IP address is a number that is automatically assigned to your computer whenever you access the Internet. When you request pages from any Services, we automatically log your IP address.
Third-Party Sources: In addition to the Personal Information that we collect directly from through your use of the Services, we may have access to other Personal Information from third-parties, depending on the privacy policies of those third-party services and the information you have authorized them to share with us. For example, we may obtain Personal Information from research and analytic companies, marketing partners, public databases, payment processors, mobile carriers, third-party login authentication, and similar third-party sources. We may also receive your Personal Information from other sources, such as people that you are in some way connected with, or our own affiliates and representatives.
How is the Personal Information that We Collect Used?
We use Personal Information in a variety of ways, including:
- To provide you access and use of the Services, including registering you as a new member or student.
- To manage our relationship with you, which includes communicating with you about your account, promotions, updates, and changes to our Terms & Conditions or Privacy Policy.
- To administer the Services, including troubleshooting, data analysis, testing, maintenance, support, reporting, and hosting of data.
- To customize or personalize your experience or identify content you share.
- For marketing, promotion and advertising purposes, including conducting analytics and aggregating data.
- To use evaluate, improve or develop our Services.
- To provide suggestions and recommendations to you that you may find interesting.
- To comply with our legal obligations and law enforcement requests.
- To fulfill contractual obligations to third parties.
- To permit you to interact with other users or representatives of ours.
- To establish or defend legal claims or protect our rights.
- To detect security incidents, prevent potentially fraudulent, illegal or harmful activities and otherwise enforcing our Terms & Conditions and other policies.
- To conduct other business analytics, research, planning, reporting or forecasting.
- For any purpose that we disclose to you at the time we collect the Personal Information
- To handle, respond to, or otherwise process any request that you make.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How is the Personal Information We Collect Shared?
Your Personal Information may be shared as follows:
- Vendors and Service Providers: We may share your Personal Information with vendors and service providers with whom we or our affiliates have a business relationship. For example, we may share your Personal Information with insurance companies, payment and credit card processing companies, accountants and legal advisors, advertising agencies and partners, and other vendors.
- Related Parties: We may disclose your Personal Information to any of our direct or indirect parents, subsidiaries or affiliates, and/or any of our or their respective parents, affiliates, subsidiaries, owners, managers, officers, directors or agents, and/or any other entity that is in common control with any of the foregoing, whether by beneficial ownership, voting power, or the ability to control or direct the management or policies of any such entity, whether by contract or otherwise.
- Merger or Acquisition: We may share your Personal Information with a third party who directly or indirectly acquires any ownership interest in us or any of our affiliates, or acquires the Services, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets.
- Permitted by Law: We may share your Personal Information if: (i) we believe that we are required to do so by law or legal process; (ii) we believe that we are permitted to do so by law or legal process; (iii) to respond to a claim; or (iv) to protect the rights, property, or safety of us, our affiliates, or others.
- With Your Consent: We may also share any Personal Information from or about you with any party if you consent to that disclosure. For example, we may need your consent to share information with a social media platform or other sharing functionality.
- Public Disclosures: We may make certain Personal Information available publicly if it is reasonably apparent at the time you submitted it that it would be shared or would be publicly available, for example, reviews or client feedback or photos you share about products or services, social media posts and similar content.
- Sales to Third-Parties: We may also sell your information to certain third-parties, including for financial compensation or other valuable consideration. In some states, you may have the right to opt-out of sales of your Personal Information. If you wish to opt out, please email [email protected]. Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize Personal Information sales. You do not need to create an account with us to exercise your opt-out rights. Please note that the “sale” of information may be defined differently in different jurisdictions, and your opt-out will only apply to the types of disclosure for which the laws in your jurisdiction require us to offer you an opt-out right. We encourage you to review these laws to understand your rights to opt-out of this type of data sharing. We do not “sell” the Personal Information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization from either the consumer who is between 13 and 16 years old, or the parent or guardian of a consumer less than 13 years old.]
The third-parties with whom we share this Personal Information may use it for their own purposes and in accordance with their own policies. We are not responsible for their actions.
Security
We take reasonable steps to help protect your Personal Information under our control. However, data transmitted over the Internet is not completely secure and we cannot guarantee the security of any information that is provided to us. If you have reason to believe that your interaction with us is not secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us (See “Contacting Us” below).
Retention, Correction and Deletion
We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
You may request that we update or correct any of your Personal Information or delete any of your Personal Information. We will respond to all requests for corrections or deletions in accordance with applicable data protection laws, but we may reject your request if we determine it is unreasonable or not required by law, or if we determine that it could expose us to operational risks or fraud. We do not charge a fee to process or respond to your 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.
[California Residents]
If you are a resident of California, you may have certain additional data protection rights regarding the access, rectification, deletion, processing, storage, portability, transfer, and restriction of your Personal Information under the California Consumer Privacy Act of 2018 (the “CCPA”), such as:
- Notice of information we collect – As we describe further above, we collect the following categories of Personal Information from you and may have disclosed this information for any of the business purposes described above (each category as defined in the CCPA): identifiers, categories described in the California Customer Records statute, commercial information, internet or similar network activity, geolocation data, audio, electric visual or similar information, and inferences drawn from other personal information.
- Request access to your Personal Information – Upon your request, we will provide you the following Personal Information over the previous twelve (12) months:
- 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 your Personal Information;
- The categories of third parties with whom we share your Personal Information;
- The specific pieces of Personal Information we collected about you; and
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- Request erasure of your Personal Information –You have the right to ask us to delete or remove your Personal Information. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. For example, we may not be able to fulfill your request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected your Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, 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;
- 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;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it; and
- Comply with applicable law and regulations.
- Right to opt-out of sale or disclosure to third-parties –You have the right to “opt-out” of our practice of disclosing or selling your Personal Information. Please see our description in this Privacy Policy above about your opt-out rights for “sales” to third-parties.
To exercise these rights, you or a person that you authorize to act on your behalf, must email [email protected]. We may require you or your authorized representative to verify your request by providing us with additional information, including providing us information to verify your identity before disclosing any Personal Information to you. This is a security measure to ensure that Personal Information 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.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We do not charge a fee to process or respond to your 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.
During the preceding 12 months, we have collected each of the categories of Personal Information we describe in the Privacy Policy above, but we have not sold Personal Information to third-parties.
If you are under the age of 18, you may request and obtain removal of any content or information that is publicly posted through any of our Services. To remove this content, please email us at [email protected] and indicate in your email the exact specific information you would like removed. Please know that this removal does not mean that all copies will be destroyed, we may retain copies for various reasons, including to comply with law.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
United States Jurisdiction
We are headquartered in the United States and the Services are exclusively for access and use in the United States and by United States residents. You consent to the transfer, storage and processing of all Personal Information we collect in the United States.
Children’s Online Privacy
The Services are intended for general audiences and are not directed to children under 13 years of age. We do not knowingly collect “personal information” as defined by the U.S. Children’s Online Privacy Protection ACT (“COPPA”) from children in a manner that is not permitted by COPPA. If we become aware that a child under 13 has provided us with “personal information” as defined by COPPA, we will delete it from our records to the extent required by COPPA. We will not be liable for any collection of children “personal information” or failure to comply with COPPA by a third party. Children can access many parts of the Services and its content and use many of its features without providing us with “personal information”. We use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Services.
Changes to this Privacy Policy
We may revise this Privacy Policy from time to time, and/or use your Personal Information for new, unanticipated uses not specified in this Privacy Policy. Should we update this Privacy Policy, updated versions of this Privacy Policy will be posted on the Website. You should review this Privacy Policy periodically, so that you can be up to date on our most recent privacy policy and procedures.
Contacting Us
If you have questions or concerns regarding the Privacy Policy or your Personal Information, please send an email to [email protected].