This policy describes how we handle your data when you use “109 World Services,” listed below:
- 109 World retreat booking pages
- Our website, 109world.com
- Our free downloadable guides, 109world.com/lifestyle
- Our email newsletter
- Our pages or ads on social media networks, like our Facebook and Instagram pages
1.What Information Do We Gather About You?
The information we gather about you depends on the context. By and large, it’s information about you that can personally identify you — either on its own or when combined with other information. The following describes the information we collect and how we obtain it.
A) Information Collected Through Times Services.
Information You Voluntarily Give Us
- For Registration:
- When you sign up for a 109 World Service (e.g., a subscription), we collect your contact information and account credentials. Once you’re registered, we assign you a unique ID number. This ID number helps us recognize you when you’re signed in.
- If you register for an event or retreat, we might ask for additional information (e.g., your DOB, your address or your dietary restrictions).
- For Billing:
- To process payments or donations, we collect and use your payment information. This can include your name, your address, your telephone number, your email address, your credit or debit card information and any other relevant information.
- For User-Generated Content:
- We offer you the ability to post content that other users can read under your profile on the 109 World website (e.g., comments or pictures). Anyone can read, collect and use any personal information that accompanies your posts.
- We do not have to publish any of your content. If the law requires us to take down, remove or edit your personal information, we will comply to the required extent.
- For Contests, Campaigns and Special Offers:
- When you sign up for these, you give us your name, email and any other required information.
- For Experience Programs:
- We gather information through questionnaires, surveys and feedback programs.
- Personal Contacts Data:
- We never scan your device for your contacts or upload that data.
- With your consent, we do comply with your requests to collect data about your friends, family or acquaintances (e.g., Refer a Friend campaigns). By using it, you acknowledge and agree that you have everyone’s consent for us to use their contact information.
Information Collected Automatically
- With Tracking Technologies in Your Browser and Mobile Apps:
- These technologies include cookies, web beacons, tags and scripts, software development kits (or SDKs) and beyond.
- We track and store data about how you visit and use 109 World Services, particularly through our websites and apps. The items we log include:
- Your IP address
- Your location
- Your operating system
- Your browser
- Your browser language
- The URLs of any pages you visit on our sites and apps
- Device identifiers
- Advertising identifiers
- Other usage information.
- If your browser doesn’t accept our cookies, you can’t access certain parts of our website. Because the “Do Not Track” browser-based standard signal has yet to gain widespread acceptance, we don’t currently respond to those signals.
B) Information Collected From Other Sources.
- Privately Owned Databases:
- Marketing, data analytic and social media-owned databases give us access to a range of information — like public data, survey data and beyond. This data sometimes includes your mailing address, your gender, your age, your household income and other demographic data.
- Social Media Platforms and Other Third-Party Services:
- (Social media platforms include Facebook. Third-party services include Google, Safari, etc.)
- We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles.
2. What Do We Do With The Information We Collect About You?
A) We provide the Times Services.
We use your information to help you use and navigate 109 World Services, such as:
- Arranging access to your account
- Providing customer service
- Responding to your inquiries, requests, suggestions or complaints
- Completing your payments and transactions
- Sending service-related messages
- Letting you take part in paid services, promotions, surveys, and free downloads.
B) We Allow You to Share User-Generated Content.
Any information you disclose in your 109 World profile becomes public — along with your chosen screen name and uploaded photo.
C) We Develop Products and Services, and Do Analysis.
We analyze data on our users’ subscription, purchase and usage behaviors. This helps us make business and marketing decisions.
For example, our analysis lets us predict preferences and price points for our products and services. It helps us determine whether our marketing is successful. It also shows us characteristics about our users.
Google Analytics is one of the analytics providers we use. You can find out how Google Analytics uses data and how to opt out of Google Analytics.
D) We Carry Out Administrative Tasks.
- For auditing: We verify that our internal processes work as intended and comply with legal, regulatory and contractual requirements.
- For fraud and security monitoring: We detect and prevent cyberattacks or unauthorized robot activities.
The above activities can involve outside companies, agents or contractors (“service providers”) with whom we share your personal information for these purposes (discussed further below).
E) We Offer Contests and Other Promotions.
You can take part in our contests and other promotions. Some might have additional rules about how we use and disclose your personal information.
F) We Advertise 109 World Services to You.
We serve ads through social media, websites, and services operated and owned by third parties. Often these ads are targeted at people who have visited or registered for a 109 World Service but have not subscribed or purchased anything. The ads are also targeted at people with similar traits or behaviors to our subscribers or customers.
We target our advertising to these users by uploading an encrypted customer list to a third party, or by incorporating a tracking technology from a third party onto our 109 World Service. The third party then matches individuals who appear in both our data and their data. Because of how this matching process works, the third party can’t read our encrypted customer list if they don’t already have it.
To opt out of receiving these matched ads, contact the applicable third parties. For example, when we use “Custom Audience” to serve you our ad through Facebook, you should be able to hover over the box in the right corner of that Facebook ad and opt out. We are not responsible for any third party’s failure to comply with opt-out requests.
We periodically send you targeted email newsletters or promotional emails. For information on opting out of these emails, see What Are Your Rights?
G) We Aggregate (or De-identify) Personal Information Into Larger Findings.
Sometimes we aggregate or de-identify information so that it can no longer identify you, under applicable laws. This helps us better understand and represent our users, such as when we measure ad performance, create advertising interest-based segments or compile survey results. We can use and disclose this aggregated or de-identified information for any purpose, unless an applicable law says otherwise.
3. With Whom Do We Share the Information We Gather?
A) With Service Providers:
We work with service providers, as defined above, to carry out certain tasks:
- Processing your payments
- Fulfilling your orders
- Maintaining technology and related infrastructure
- Offering you customer service
- Serving and targeting ads
- Measuring ad performance
- Presenting surveys
- Shipping you products and mailings
- Distributing emails
- List processing and analytics
- Managing and analyzing forms
- Managing promotions
When performing these tasks, service providers often have access to your personal information.
B) With Other Third Parties:
There are situations when we share your information with third parties beyond our service providers. We never share your email address with these third parties without your consent, except in encrypted form to engage in the matched ads process described above.
We share information about participants in our giveaways, contests and similar promotions with the promotions’ sponsors. In those cases we notify you when you provide us the information.
We process payments you make through 109 World Services with external services.
There are two ways this can happen:
- We collect your information and share it with the third-party service for processing. The third-party service collects your information for processing.
- We can preserve or share personal information if the law requires us to do so. We can also preserve or share personal information if we believe it would be necessary to:
- Comply with the law or with legal process
- Protect and defend our rights and property
- Protect against misuse or unauthorized use of the 109 World Services
- Protect the safety or property of our users or the general public (e.g., if you provide false information or attempt to pose as someone else, we could share your information to help investigations into your actions)
- Cooperate with government authorities, which could be outside your country of residence.
- We disclose public activities in our RSS feeds, APIs and other distribution formats. Your public activities could thus appear on other websites, blogs or feeds.
4. What Are Your Rights?
A) How Do I Opt Out of Email, Phone, and Mail?
The opt-out methods described below are limited to the email address, phone or device used. They won’t affect subsequent subscriptions.
- We offer a variety of commercial emails and email newsletters. You can unsubscribe from them by following the “unsubscribe” instructions near the bottom of the email. You can also email us at [email protected]
- You can manage your 109world.com newsletter preferences.
- Text Messages:
- You can opt out of text alerts any time by replying “STOP,” or any alternative keyword we’ve shared with you.
We complete any opt-out request as quickly as we can. This opt-out request won’t prohibit us from sending you important nonmarketing notices.
B) How Do You Access, Change, Delete, Update or Exercise Your Other Rights in Relation to Your Personal Information?
In some parts of the world, you have the right to:
- Access, modify, or delete the personal information we have about you
- Receive an electronic copy of the personal information we have about you, for data portability
- Restrict, or object to, how we process personal information about you
- Not receive discriminatory treatment by us for the exercise of your privacy rights
- You have the right to object to the processing of your personal information based on our legitimate interest or that of a third party — unless we demonstrate compelling legitimate grounds for the processing of, or the keeping of, your personal information for the establishment, exercise or defense of legal claims.
If you’d like to exercise any of the above rights, contact us via email at [email protected] In your request, please be specific. State the information you want changed, whether you’d like your information suppressed from our database or whether there are limitations you’d like us to put on how we use your personal information. Please use the email address linked to that personal information — we only complete requests on the information linked to your email address. To verify your identity, we will email the email address you provide us, and which matches our records, and wait for your response. In some instances we may also ask for additional information. This is how we verify your identity before complying.
You can designate an authorized agent to make a request on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.
We’ll respond to your request in a manner consistent with applicable law.
We might need to keep certain information for recordkeeping purposes, or to complete a transaction you began prior to requesting a change or deletion (e.g., if you make a purchase or enter a promotion, you might not be able to change or delete the personal information provided until after the completion of the purchase or promotion).
In some cases, your request doesn’t ensure complete removal of the content or information (e.g., if another user has reposted your content).
C) How Do You Manage Your Digital Accounts?
You can update your account information and see your transaction history. If you need assistance, email us at [email protected]
5. What About Sensitive Personal Information?
We generally don’t want to gather any sensitive information about you. This includes:
- Your social security number
- Your racial or ethnic origin
- Your political opinions
- Your religion or other beliefs
- Your health, biometric or genetic characteristics
- Any trade union membership
- Any criminal background
- There are rare situations when we request this information (e.g., a participant survey), but you can decline to answer. Outside those situations we would prefer you never share that information with us.
6. How Long Do You Retain Data?
It depends. We store your personal information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). This means we might retain your personal information even after you close your account with us.
- When deciding how long to keep your information, we consider:
- How long we have had a relationship with you or provided a 109 World Service to you
- Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them)
- Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).
- Rather than delete your data, we might de-identify it by removing identifying details.
7. How Do You Protect My Information?
We protect your personal information with a series of organizational, technological and physical safeguards — but we cannot guarantee its absolute security. We recommend that you use complex and unique passwords for your 109 World accounts and for third-party accounts linked to them. Do not share your password with anyone.
If you have reason to believe your interaction with us is no longer secure, notify us immediately.
8. Are There Guidelines for Children?
109 World Services are intended for a general audience, and are not directed at children under (13) years of age.
We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or COPPA) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at [email protected] We will remove the data to the extent required by applicable laws.
9. What Is Our Legal Basis?
In some jurisdictions, like the European Union and the European Economic Area, we only collect, use or share information about you when we have a valid reason. This is called “lawful basis.” Specifically, this is one of the following:
- The consent you provide to us at the point of collection of your information
- The performance of the contract we have with you
- The compliance of a legal obligation to which we are subject or
- The legitimate interests of 109 World or a third party. “Legitimate interest” is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights and interests. “Legitimate interest” also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact.
We have a legitimate interest in gathering and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within 109 World; (3) to prevent fraud; and (4) to conduct our marketing activities.
10. What About Links to Third-Party Services?
If we make a significant or material change in the way we collect, use or share your personal information, we will notify you at least 30 days prior to the changes taking effect. We will do this via email. If you object to any change, you can stop using the 109 World Services.
12. How Can You Contact Us?
If you have any questions, email us at [email protected]