ASD Transformation Secrets

Privacy Policy

The ASD Transformation Secrets and Empower Youth Consultants have created this
privacy policy in order to demonstrate the importance of your privacy and protection of
the personal information that we collect and process. The following discloses ou
information gathering and dissemination practices. We take your privacy and security
very seriously. Please read our privacy policy carefully to understand the ways in which
we are protecting your important information.
If you have any questions regarding our privacy policy, please reach out to
In order for us to operate our business and provide our services to You, it is sometimes
necessary for us to collect or process information about You. In general terms, this
information will take one or more of the following forms:

  1. Information that you provide to us directly, such as in the situation where you
    complete an online form or send us a message via our website.
  2. Information that is automatically sent to us by Your computer’s internet browser
    when you visit our website, such as your computer’s technical address (or ‘IP
    address’) or information about which particular internet browser you are using and
    so on;
  3. Information about how you use our website or our services, such as which pages
    you visit, how frequently you visit the site and so forth.
    If you send us a message via our website’s online contact form, we need to collect
    certain data from you (your name and email address). We need to use this information
    to respond to your request – but we will also always ask for your consent to process this
    data before you submit the enquiry, and you will see a link to this Privacy Policy.
    We will not use this data for any other purpose unless you have given us your additional
    permission to do so. We will not share this information with anyone outside of the
    This privacy policy sets out the detail of what information we collect, as well as how that
    data is used and protected.
    This privacy policy has been compiled to better serve those who are concerned with
    how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as

described in US privacy law and information security, is information that can be used on
its own or with other information to identify, contact, or locate a single person, or to
identify an individual in context. Please read our privacy policy carefully to get a clear
understanding of how we collect, use, protect or otherwise handle your Personally
Identifiable Information in accordance with our website.
Our commitment to data privacy
We are fully committed to maintaining the privacy of any information (‘personal data’)
that you provide to us. Furthermore, we commit to ensuring that such data is held
securely, used appropriately and only retained for as long as is necessary.
Our systems and services are designed with privacy in mind, and we operate a ‘data
minimization’ principle wherever possible – that is to say that we will only ever ask you
for the minimum amount of information required to provide our services efficiently; we
have no desire to retain (and therefore maintain) any more information than is
necessary. We aspire to comply to the fullest extent possible with applicable data
protection regulations, in particular the European Union’s General Data Protection
Regulation (‘GDPR’) and ePrivacy Directive, where applicable.
What personal information do we collect from the people that visit our blog,
website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter
your name, email address, mailing address, phone number or other details to help you
with your experience.
When do we collect information?
We collect information from you when you place an order, subscribe to a list, fill out a
form, or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, make a purchase,
sign up for our free resources, respond to a survey or marketing communication, surf
the website, or use certain other site features in the following ways:
ï‚· To quickly process your transactions.
ï‚· To ask for ratings and reviews of services or products
ï‚· To follow up with them after correspondence (live chat, email or phone inquiries)

We may use your personal information to contact you via email, or telephone in order to
give you updates about our special events, new services, current information regarding
our products, or other promotions that may be of interest to you. We also use return e-
mail addresses to answer any emails we receive from you. Your e-mail address will not
be used for any other purpose or shared with outside third parties for their direct
marketing purposes. We may also use your IP address to help protect Program
Certification Formula and our Internet Service Providers from fraud.
We may also use non-personal aggregate information to improve our Web sites. For
example, our Internet Service Providers may report to us that there were a particular
number of visitors to a certain area of our Web sites, or that a certain number of
businesses or a certain number of individuals completed our registration forms in
particular areas of our Web site. Such information may also be used to analyze the
effectiveness of our business and advertising models.
We may also disclose your personal information as is necessary to: (a) comply with a
subpoena or court order; (b) cooperate with law enforcement or other government
agencies; (c) establish or exercise our legal rights; (d) protect the property or safety of
our company and employees, contractors, vendors, suppliers, and customers; (e)
defend against legal claims; (f) help with internal and external investigations; or (g) as
otherwise required by law or permitted by law. We may disclose your information in
connection with the sale or merger of Program Certification Formula or any transaction
that involves the sale or assignment of some or all of our assets.
How your data is protected
We take the security of all personal data very seriously, and that data is protected in a
number of ways:
ï‚· Access control: access to personal data is strictly limited in line with our policy
detailed in the ‘who we share data with section’ on this page. Access is controlled
by individual user accounts, where a strong password policy is enforced
ï‚· Dedicated security software: We operate dedicated security scanning and
access control software on all of our websites. This software is responsible for
limiting login attempts to our site, blocking potentially malicious attempts to access
our services, and regularly performing full file system scans.
ï‚· Data encryption: where data is stored in a cloud facility (such as the storage of
website backup files), that data is encrypted both ‘in transit’ and ‘at rest’ – meaning
that all data is securely obscured both during the process of transfer to the cloud
provider, and then additionally when it is in storage at its final location.
ï‚· This website is also secured with SSL encryption, which means that all traffic to
and from our servers is encrypted. This applies to our own administrative access to
the website as well as that of users of our services.

ï‚· Additionally, we ensure that our own dedicated secure Virtual Private Network
(VPN) is used when we access the site from anywhere on a public wifi network.
ï‚· Selection of third-party service providers: we use a very limited number of third
party service providers, but some are essential for the provision of physical hosting
environments and cloud services. One of the core factors in the selection of such
providers is their ability to provide secure systems and processes. We have written
Data Processing Agreements with each of our core service providers that sets out
the requirements for data security.
ï‚· Our website is scanned on a regular basis for security holes and known
vulnerabilities in order to make your visit to our site as safe as possible.
ï‚· We do not use Malware Scanning.
ï‚· We may use an SSL certificate, but we do not collect credit card numbers.
Access to your personal data
ï‚· In the situation where you have directly provided personal information to us (such
as by completing an online form or contacting us for further information), you have
a number of rights regarding the personal data that we hold:
ï‚· You have the right to obtain from us confirmation about whether any such data is
being held.
ï‚· You have the right to require that we provide you with whatever data we are
holding/processing about you, including the right for that data to be transferred to
another data controller.
ï‚· Even if you have consented to Us processing your personal data, you have the
right to withdraw that permission at any time.
ï‚· You have the right to require us to rectify any incomplete or incorrect information
held about you.
 You have the right to require us to erase the data held about you (the ‘right to be
ï‚· In the situation where we collect personal data automatically (such as from your
internet browser or via internet Cookies or other similar technologies):
ï‚· You have the right to object to the legal basis upon which we are collecting this
data, and We have an obligation to consider and respond to that objection.
ï‚· You have the right to request the prevention of further processing of your data
while your objection is considered.
ï‚· You have the right to make a complaint to the relevant data protection authority
(which, in the UK, is the Information Commissioner’s Office or ‘ICO’)
ï‚· In most circumstances, you can exercise these rights without paying a fee to us.
ï‚· Types of data collected

Website contact forms
When you complete one of the contact forms on our website, we will ask you for a
number of pieces of personal information, such as your name, email address and other
contact details. This is obviously required for us to respond to your request.
If you do not use or submit an online form on the website, no data will be collected in
that regard.
Account logins
For some website functionality, we will need to create for you a user account that allows
you to login to the site to ensure that only authorized individuals can access your data
and that functionality. Examples include when you make an online purchase via the site,
or when you have a role in administering or contributing towards the website content
(such as a blog author). The purpose of these user accounts is to protect your personal
data behind login security, and to protect the integrity of our site and the servers that run
Data collected will generally involve your name and email address (which doubles as
username) as a minimum but may include your postal address if it is required for online
If you do not register for an online account, then no such data will be collected in this
Technical data (such as ‘IP address’)
When you visit our website, our systems will log a record of your visit in our server logs,
and typically this record will include the technical ‘IP’ address that is associated with
your device and the browser type and version that you are using.
Such server logs are extremely common practice, and are used to monitor technical
resources, monitor high-level server activity, and importantly to detect and prevent
malicious or fraudulent activity on our systems. This data can also be used, if required,
to diagnose reports of technical issues. The storage of IP addresses allow us to identify
patterns of behavior (such as repeated malicious attempts to access a system).
IP addresses, in and of themselves, do not allow us in any way to identify you as an
individual, especially given that it is very common for IP addresses to be dynamically
allocated by your service provider, and will therefore often routinely change.

Furthermore, we do not and will not use the content of server access logs to attempt to
determine an identifiable individual. We therefore do not consider that data held within
server logs falls within the scope of ‘personal data’, and accordingly we do not seek
your consent to collect it.
We have included cookies, web beacons and similar technologies into one section
because they all perform similar functions even if, from a technical perspective, they
work slightly differently.
All of these technologies allow us to better understand how users are using our website
and other related services. They can also be an essential part of providing certain online
functionality. They are all essentially small data files placed on your computer (or other
device) that allow us to tell when you have visited a particular page or performed a
particular action (such as clicking a particular button) on our website.
These technologies are used by most websites as they provide useful insight into how
the services are being used, as well as improving speed, performance and security, and
enabling us to improve our personalization of your experience.
Cookies are small text files placed in the memory of your browser or device when you
visit a website. Cookies allow a website to recognize a particular device or browser.
There are several types of cookies:
ï‚· Session cookies expire at the end of your browser session and allow us to link
your actions during that particular browser session.
ï‚· Persistent cookies are stored on your device in between browser sessions,
allowing us to remember your preferences or actions across multiple sites.
ï‚· First-party cookies are set by the site you are visiting.
ï‚· Third-party cookies are set by a third-party site separate from the site you are
There are a number of ways that you can influence how cookies are used on your
particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet
Explorer, Firefox etc.) allow you to set preferences for whether to allow or block website
They will also provide tools that allow you to remove any cookies that have already
been set. Using the ‘Help’ functionality of your browser, or an Internet search, will help
you to understand how to use these features for your particular browser.

You can choose to have your computer warn you each time a cookie is being sent, or
you can choose to turn off all cookies. You do this through your browser settings. Since
browser is a little different, look at your browser’s Help Menu to learn the correct way to
modify your cookies.
If you turn cookies off, some features will be disabled. It won’t affect the user’s
experience that make your site experience more efficient and may not function properly.
However, you will still be able to place orders.
Third-party disclosure
We do not sell, trade, or otherwise transfer to outside parties your Personally
Identifiable Information.
Third-party links
Occasionally, at our discretion, we may include or offer third-party products or services
on our website. These third-party sites have separate and independent privacy policies.
We therefore have no responsibility or liability for the content and activities of these
linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any
feedback about these sites.
Google’s advertising requirements can be summed up by Google’s Advertising
Principles. They are put in place to provide a positive experience for users.
Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of
the DART cookie enables it to serve ads to our users based on previous visits to our
site and other sites on the Internet. Users may opt-out of the use of the DART cookie by
visiting the Google Ad and Content Network privacy policy.
Website Analytics
We use Google Analytics to better understand what people look at on our website.
When people visit our site, information about their visit (such as which pages they look
at, how long they spend on the site and so on) is sent in an anonymous form to Google
Analytics (which is controlled by Google).

The data contains information about anyone who uses our website from your computer,
and there is no way to identify individuals from the data.
We ensure that no personally identifiable information is ever contained within the data
sent to our analytics providers, and we also perform a process, which partially obscures
your IP address information.
As analytics information is not personal data, we do not specifically ask for your prior
Like the vast majority of commercial websites, we use social media cookies from
Facebook on our site. The cookies are placed by Facebook, and we use them to
understand the effectiveness of social media campaigns that we operate.
If you are not logged into Facebook when you view our site, then it is not possible for
any personal information about your visit to be collected, and therefore we do not
specifically ask for your prior consent.
If you are logged into Facebook when you view our site, then Facebook will know when
you visit us. We do not have any access to the detail of that personal data, as you have
consented to share it with Facebook, not us. We just get to see anonymized data about
the numbers of people who have responded to our advertising or other social media
You can learn about Facebook’s privacy policy here.
Facebook may use cookies, web beacons, and other storage technologies to collect or
receive information from your websites and elsewhere on the internet and use that
information to provide measurement services and target ads. You can learn about
Facebook’s privacy policy here.
There are a number of ways of controlling the ads that you see based upon your activity
on Facebook. The following resources may help to understand those choices:
ï‚· You can opt-out of Facebook tracking on the _ website using the
Cookie Control functionality on this site. You can edit your cookie preferences at
any time using the Cookie Control icon in the bottom right hand corner of your
screen, and disabling ‘marketing’ cookies.
ï‚· How to opt-out of Facebook interest-based advertising on your browser or mobile
ï‚· About Ads:

ï‚· Your Online Choices:
You can always use your browser’s ‘private’ or ‘incognito’ mode to browse websites
We have implemented the following:
Demographics and Interests Reporting
We, along with third-party vendors such as Google use first-party cookies (such as the
Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or
other third-party identifiers together gather data concerning traffic sources and visitor
Opting out:
Users can set preferences for how Google advertises to you using the Google Ad
Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative
Opt Out page or by using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online
services to post a privacy policy. The law’s reach stretches well beyond California to
require any person or company in the United States (and conceivably the world) that
operates websites collecting Personally Identifiable Information from California
consumers to post a conspicuous privacy policy on its website stating exactly the
information being collected and those individuals or companies with whom it is being
shared. – See more at:
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a
minimum, on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page
specified above.
You will be notified of any Privacy Policy changes:
ï‚· On our Privacy Policy Page
ï‚· You can change your personal information:

ï‚· By emailing us
ï‚· By calling us
How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising
when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of
13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in
control. The Federal Trade Commission, United States’ consumer protection agency,
enforces the COPPA Rule, which spells out what operators of websites and online
services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United
States and the concepts they include have played a significant role in the development
of data protection laws around the globe. Understanding the Fair Information Practice
Principles and how they should be implemented is critical to comply with the various
privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive
action, should a data breach occur:
We will notify you via email within 7 business days.
We also agree to the Individual Redress Principle which requires that individuals have
the right to legally pursue enforceable rights against data collectors and processors who
fail to adhere to the law. This principle requires not only that individuals have
enforceable rights against data users, but also that individuals have recourse to courts
or government agencies to investigate and/or prosecute non-compliance by data

The CAN-SPAM Act is a law that sets the rules 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.
We collect your email address in order to:
ï‚· Send information, respond to inquiries, and/or other requests or questions
ï‚· Process orders and to send information and updates pertaining to orders.
ï‚· Send you additional information related to your product and/or service
ï‚· Market to our mailing list or continue to send emails to our clients after the original
transaction has occurred.
ï‚· To be in accordance with CANSPAM, we agree to the following:
ï‚· Not use false or misleading subjects or email addresses.
ï‚· Identify the message as an advertisement in some reasonable way.
ï‚· Include the physical address of our business or site headquarters.
ï‚· Monitor third-party email marketing services for compliance, if one is used.
ï‚· Honor opt-out/unsubscribe requests quickly.
ï‚· Allow users to unsubscribe by using the link at the bottom of each email.
ï‚· If at any time you would like to unsubscribe from receiving future emails,
ï‚· Follow the instructions at the bottom of each email.
Contacting Us
If there are any questions regarding this privacy policy, you may contact us using the
information below.
ASD Transformation Secrets
Empower Youth Consultants
385 South Lemon Avenue, E 407
Walnut, CA 91789
United States
Last Edited on 2020-02-23

© ASD Transformation Secrets

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