Last Updated March 10, 2021
The She-Suite takes your privacy seriously and is committed to protecting the privacy of the information you share with us when you access and use our websites or products.
WHO WE ARE AND OUR RELATIONSHIP WITH YOU
The She-Suite is owned by Velvet Suite, Inc., a Virginia corporation, and is a leading provider of leadership development and personal branding for women. We provide leadership training, coursework, and mentoring and facilitate workplace empowerment, personal branding and networking. We do this through a variety of online videos, online lessons and coursework, one-on-one coaching, events, and live discussion platforms.
Our “Clients” are individuals and organizations who pay for access to our Products. The persons who use our Products are “Users”. If you are just checking out our Sites and Products, then you are a “Visitor.”
HOW TO CONTACT US
phone: (800) 790-7630
mail: The She-Suite
12020 Sunrise Valley Dr.
Reston, VA 20191
INFORMATION WE COLLECT
Information We Collect From You
The information we collect from you varies depending upon whether you are our Client or a User.
Information Clients Provide To Us
When you access our Products, we may collect the following information:
- Entity Information, including the name of the business, the division or group using our Products, and business address.
- Contact Information, including the business contact person’s name, work email address, work phone number, and position or title at the company; and
- Payment Information, including information bank account and credit card information.
Information Users Provide to Us
When you access our Products, we ask you to complete a “User Profile” which includes the following information:
- Contact Information, including your name, email, phone numbers, work address;
- Demographic Information, including your work status, work industry, education, language preference, race, gender identity, age group, and ethnicity; and
- Your Photograph.
Information Visitors Provide to Us
We may ask for your name, email address, mobile number, organizational and employment information if you enquire about our Products, request more information from us, or fill out a form requesting access to or information about our Products.
Information We Collect From Your Device
Cookies And Tracking Technologies We Use
As is true of most online platforms, we gather certain information automatically and store it. This information may include your Internet protocol (IP) address, browser type (for example Safari, Microsoft Internet Explorer, Firefox, or Chrome), Internet service provider (ISP), operating system (for example, Apple macOS, Apple iOS, Microsoft Windows, or Android), and the date and time you accessed our Sites. We may link this automatically collected data to other information we collect about you so that we can provide a better user experience. For example, if you stopped watching a video in the middle, it will restart where you left off.
We partner with third parties to display advertising on our Sites and to manage our advertising on third party websites. Our third party partners may use technologies such as cookies to gather information about your activities on our Sites and other websites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You may continue to receive generic ads.
What We Track
We track your IP address, location, when and for how long you access our Sites and Products, and what Products and Sites you’ve accessed. Our Sites do not respond to “Do Not Track” requests.
NOTICE, ACCESS, AND CHOICE
You have the right to obtain a copy of the personal information we collect from you, to know what personal information we hold, to object to the collection of your personal information, and to remove, correct, transfer or delete your personally identifiable information. If you are a User who has accessed our Sites because of your relationship with our Client, such as your employer, you should contact that Client, typically your Employer, in order to exercise these rights.
We retain your personally identifiable information for as long as the information is needed to provide our Products to our Clients and for any additional period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
THE WAY WE USE YOUR INFORMATION
We use the personal information you provide to us as follows:
- To ensure our Products are relevant and effective.
- To deliver our Products.
- To allow Clients to know how and when their employees have accessed our Products.
- To help us improve our understanding of behavior, so that we can create better leaders.
- To create educational and training tools.
- To alert you to product upgrades, special offers, updated information and other new services.
- To allow access to our Sites as appropriate.
- To send important status and service messages regarding our Products and Sites.
We use your device data, demographic and professional data, in an aggregated, de-identified manner – which means that it cannot be attributable specifically to you – for research purposes so that we can improve our understanding of behavior and improve our Products.
We use your responses and behavioral information that you provide to us when you access our Products, in a pseudonymous manner – which means that your identity is hidden — for research and diagnostic purposes to provide so that we can improve our understanding of behavioral trends and improve our Products.
We use your device data, demographic and professional data on an individual basis in a manner that may identify you for The She-Suite Brand Leadership Institute in order to measure your annual progress.
We use your name and email address to send marketing emails, unless you “unsubscribe” or opt-out of receiving these emails.
HOW WE SHARE YOUR DATA
We share data we collect with third parties to help us maintain our Sites and provide our Products. These companies are authorized to use personal information only as necessary to provide these services to us. These services may include:
- Providing login and Site security,
- Fulfilling orders,
- Payment processing,
- Providing customer service,
- Sending marketing communications,
- Fulfilling service requests,
- Conducting research and analysis, and
- Providing cloud computing infrastructure.
We also share your information with third parties under the following very limited circumstances:
User Information with Client. Our business is to provide training, and analysis to enable individuals and organizations to perform more successfully. Accordingly, if you have accessed our Products because of your relationship to our Client, we may share your personal information with that Client in an aggregated, pseudonymous manner – which means that your identity is hidden. For example, if you accessed our Products through your employer, we may share your personal information with your employer.
As you Explicitly Allow: We may share information about you as you explicitly allow. For example, before taking part in a survey hosted by our third-party partner or using our two-factor authenticator, you will be asked to consent by clicking a pop-up form.
Agents Acting on Our Behalf: We may share some of your information with other business partners who provide us with technical services. They will be granted access to only that information which is necessary for them to do their jobs. Any agents to whom we grant access to personal information are contractually barred from using or releasing that information outside of the specific task we have asked them to perform. We have various agreements, policies, safeguards and certifications to ensure that these agents do not sell, distribute or use this information.
Payment Services: We process payments through ACH transactions or Paypal. For ACH payments, we request your bank account information and transfer it to the ACH network. For Paypal, our Sites will capture credit card information and transfer it to Paypal. Please visit Paypal to learn more about their privacy and security features.
Surveys: We us a third party service, Alchemer, to survey and report on User experience. The survey is optional but helps us determine if our Sites and Products are useful and relevant. If you participate in the survey, Alchemer will collect your survey answers, device information, referral source (which link referred you to the survey), and page tag data, which may include the type of device you use, search themes, and click rates. Please visit the Alchemer to learn more about their privacy practices.
For Legal Reasons: We may disclose your information pursuant to judicial or other government subpoenas, warrants, orders, bankruptcy proceedings or similar legal process. We may also disclose your information if it is required to comply with the law, or with legal process served upon us, defend our legal rights or our property, or to act in urgent circumstances to protect the personal safety of our clients, employees, partners, or members of the public.
Acquisition: We may share information for purposes of an acquisition or merger of or by our company.
HOW YOU SHARE YOUR DATA WITH THIRD PARTIES
Links to Third Party Websites
Our Sites may include social media links, features and widgets, such as Facebook, Instagram, LinkedIn and Twitter, or interactive mini-programs. These features may collect your IP address, which page you are visiting on our Sites and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy statements of the companies providing the features and, depending upon their policies and agreements, they may share information they collect about you with us.
Q & A Forums, Events, and Blogs
Our Sites offer publicly accessible Question and Answer Forums, events and blogs. You should be aware that any information you provide in these areas is public and may be viewed, read, collected, and used by others who access them. We do not have access to or control of the information or questions you or others post. If you want to delete your comments or questions, email us at firstname.lastname@example.org.
We post Client testimonials on our Sites which may contain personal information such as your name, attributable quotes or videos of you. We obtain your consent to post your name along with your testimonial prior to posting the testimonial.
HOW TO OPT-OUT
You may opt out and forbid our use of your personally identifiable information by emailing us at email@example.com. If you opt out or forbid our use of certain information, you may not be able to use our Products, or the functionality of the Products may be diminished.
HOW WE KEEP YOUR INFORMATION SAFE
The She-Suite does not maintain any physical servers or storage systems of our own. We partner with SiteGround for our computing power and database storage. We do not have access to our partner’s physical servers or storage systems. To learn more about their privacy practices and security systems visit SiteGround.
Our Commitment to Data Security
Our Sites have security measures in place to help protect against the loss, misuse, and alteration of the data under our control. We use Secure Socket Layer (SSL) technology to protect information using both server authentication and data encryption to help ensure that your information is safe and secure. We also implement an advanced security method based on dynamic data and encoded session identifications, and host our Sites, in a secure server environment that uses firewalls, passwords, and other advanced technology to prevent interference or access from outside intruders. We use a two-factor authentication system provided through miniOrange. We train employees and monitor access to our Sites. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of your information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
HOW TO ACCESS OR CORRECT YOUR INFORMATION
While your account is active, you can change, update, correct or delete your account information by logging into your account and updating your user profile and account settings. Upon request we will provide you with information about whether we hold any of your personal information. To get a record of your personally identifiable information or request that we change or delete your account or personally identifiable information, please contact us by email at firstname.lastname@example.org. We will respond within 30 days after we receive your request.
Our Products are not designed for minors or children under age 13 and we do not knowingly collect information from children. If we discover that a minor or child under 13 has signed up for our Products or provided us with personally identifiable information, we will the delete that child’s personally identifiable information from our records.
CHANGES TO THIS STATEMENT
EU USERS – GDPR
To our EU Users, we are committed to complying with the General Data Protection Regulation and partnering with other businesses that share our commitment to privacy and compliance with the GDPR.
The She-Suite is located in the United States. Personal Data we collect from you will be processed in the United States. The United States has not sought or received a finding of “adequacy” from the EU under Article 45 of the GDPR. We rely on derogations for specific situations as set forth in Article 49 of the GDPR.
We may be a “Data Processor” or “Data Controller”. To learn more about what these terms mean, click here. To learn more about what the term “Personal Data” under the GDPR means click here.
Basis for Transferring Your Data
Your Personal Data is transferred to us for the following reasons:
- You consented to the transfer;
- The transfer is necessary to perform a contract to which you are or will become a party;
- The transfer is necessary for compliance with a legal obligation to which the Data Controller (in most cases this is our Client) is subject;
- The transfer is necessary in order to protect your vital interests or the vital interests of another natural person.
- The transfer is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; or
- The transfer is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.
Basis of Processing Special Categories of Data
Our Products are designed to help women from different backgrounds succeed in the workforce. Therefore, we ask you questions (some of which are optional) pertaining to, or that might reveal, your race, ethnic background, political opinions, religious or philosophical beliefs, trade union membership or sexual orientation (“Sensitive Personal Data”). We process that Sensitive Personal Data if:
- We have your explicit consent to process such data for a specified purpose;
- Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or data subject in the field of employment and social security and social protection law in so far as it is authorized by the EU or member state or a collective agreement pursuant to member state law;
- Processing is carried out in the course of the controller’s legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects;
- Processing relates to Personal Data which are manifestly made public by the data subject; or
- Processing is necessary for the establishment, exercise or defense of legal claims;
- Processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law;
- Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3, Article 9 of the GDPR;
- Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy; or
- Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
Where Your Data Is Processed
Your data is processed in the United States.
You have the right to:
- Refuse or object to the processing of your Personal Data.
- To access the Personal Data we process.
- To be forgotten and have your Personal Data erased.
- To lodge a complaint with your Data Protection Authority.
If you are a User and not our Client, and wish to exercise any of these rights, please contact the Client through which you are accessing our Products – usually this is your employer. If you are our Client and wish to exercise any of these rights, please contact The She-Suite at email@example.com.
Refusal to Provide Data.
If an employer has requested that you use our Products and you do not provide all required data or fail to complete the development program, there may be employment, or professional consequences to you. Please check with the employer to determine what those consequences might be.
How We Received Your Contact Information.
If you are a User and received an invitation to use our Products, we received your email or other contact information from your Employer.
We offer you a means to choose how we may use your Personal Data. If you change your mind about receiving information from us or about sharing your Personal Data with third parties, send us a request specifying your new choice. Simply email, call or write us. Our contact information is located in the “Contact Us” section at the beginning of this statement. Please see How to Opt-Out or more information about our opt-out policy.
We retain your Personal Data for as long as the information is needed to provide Products and for any additional period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We ask for your explicit consent to use your Personal Data when you access our Products.
If you are a Client and wish to request that we no longer use your Personal Data contact us at firstname.lastname@example.org. In most cases, we will delete your Personal Data within thirty (30) days of the date of your request. If you are not a Client and would like to request that we no longer use your Personal Data, please contact your Data Controller. Your Data Controller is typically the person or entity that granted you access to our Products, such as an employer.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact email@example.com.
This section provides details about rights California consumers may exercise under the California Consumer Privacy Act (CCPA) and other California privacy and data protection laws, as applicable.
Under the CCPA, California consumers have the following rights:
The right to request to know more about the categories and specific pieces of “Personal Information,” as defined by the CCPA, that we have collected about them and how that information has been used over the past 12 months. They may also request a copy of this information, free of charge.
The right to request that we delete Personal Information that we have collected about them, subject to certain exceptions.
If a business sells Personal Information, the right to opt-out of the sale. At The She-Suite, we do not sell Personal Information that we collect about our users, as provided in the CCPA.
The right not to be discriminated against if you choose to exercise any of these rights.
Under California’s ‘Shine the Light’ law, California residents have the right to request certain information relating to “Personal Information”, as defined here, that we have shared with third parties for those third parties’ direct marketing purposes.
If you are a California resident and would like to exercise your rights under the CCPA or California’s ‘Shine the Light’ law, email us at firstname.lastname@example.org and include your mailing address and state of residence.