This policy was updated and is effective as of November 26, 2020.
You can quickly access sections of this policy by selecting any of the following:
Life Transitions by Dr. Amy, Inc. (“Company”, “we”, “our”, “us”)
Website (https://www.dramy.life/), mobile website, product pages, courses, and programs (collectively, “Sites”).
Services, memberships, products, events, and webinars offered on our Sites (collectively, “Services”)
Third Party sources, online service providers, data processors, course and product hosting platforms, payment services, and other third parties (collectively, “Third Parties”, “Third Party”)
“Anonymous Data” means data that is not associated with or linked to any individual’s Personal Information or will not easily permit the identification of individuals.
“Personal Information” means any data that identifies an individual. In some instances, Anonymous Data can be extracted from Personal Information supplied, such as general location or type of transaction.
Through standard operation of our Sites and Services, we automatically record certain Anonymous Data. The information gathered may include the type of web browser being used, operating system, and IP address. We may share such information with our business and promotional partners as necessary for legitimate business interests, including enhancing your experience with our Sites and Services.
We may ask for Personal Information when you use various features of our Sites and Services, such as joining a mailing list, registering for a course or webinar, purchasing products, downloading special offers, or taking surveys. The type of Personal Information we collect may include, but is not limited to:
Why we collect Personal Information
We will use and disclose the Personal Information that we collect for the purposes for which it was collected in connection with our business and in accordance with applicable laws for the following purposes:
How we obtain Personal Information
We may collect your personal information when you voluntarily provide it to us by using our Sites and Services, or from third party sources (see following section). For example, we may ask you to provide personal information if you:
If you speak with one of our representatives by telephone or online audio or video conferences, the conversation may be recorded or monitored. We do this for the following reasons:
Limiting collection of Personal Information
In order conduct our business operations, we use various Third Party sources to assist in delivering our Sites and Services.
We may receive your Personal Information from Third Party sources which could include, but is not limited to, payment transaction services, course hosting platforms, and content providers. You authorize the collection of your Personal Information from these sources and, if applicable, you authorize these sources to give us your Personal Information for the above-mentioned purposes.
These Third Parties may provide and publish content to you or us via their websites or services and shall be deemed the data controllers for any Personal Information contained in their content. For example, you may have a PayPal account, which you access to make a payment to us. These Third Parties may include, but are not limited to:
We will not use your Personal Information without your consent for purposes other than those for which it was collected or in accordance with applicable laws.
With your permission, we may use your contact information to send you information about our company and products. You may always opt-out of receiving future information, as provided below.
We may generate Anonymous Data from Personal Information collected through our Sites and Services by removing information that makes the data personally identifiable to an individual. Such Anonymous Data includes, but is not limited to, information we collect from your use of our Sites and Services. We may use this Anonymous Data and aggregated data for any reasonable purpose subject to applicable laws and disclose such data to third parties in our sole discretion.
In some circumstances, we may use and disclose your Personal Information to service providers, data processors and other Third Parties under the following limited circumstances:
We use Third Parties to process payment transactions through our Sites for Services. We have used commercially reasonable efforts to select appropriate Third Parties that will maintain the confidentiality and security of payment information that they may collect from you, such as your credit card numbers, expiration dates, and any other Personal Information necessary to process your payment. We and the Third Parties may send emails to you regarding the processing of your online payment.
Our Company does not save your complete payment information as we use tokenization. Your payment information is encrypted and sent directly from your web browser to the Third Parties who then provide us with a token. This token does not contain any sensitive data and is used to facilitate the payment process. Please note that we may keep a portion of your credit card number as well as the type of credit card you use to purchase our Services for verification and refund purposes.
Third Parties we are currently using include:
Shopify Inc.: https://www.shopify.com/legal/privacy/customers
PayPal Holdings, Inc.: https://www.paypal.com/us/webapps/mpp/ua/privacy-full
Stripe, Inc.: https://stripe.com/en-ca/privacy
Your use of these Third Party payment processors is governed by their policies which are agreements between you and those Third Parties.
If you have any questions or concerns about your payment information or your agreement with Third Party payment processors, please contact them directly at the web addresses provided above.
By engaging Third Parties to perform and provide certain services on our behalf, these Third Parties may store, process, and transfer Personal Information on servers located in various locations, such as, but not limited to the United States of America, Canada, the United Kingdom, or within the European Union. As a result, Personal Information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions.
For example, Personal Information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Parties to maintain protections on Personal Information that are equivalent to those that apply in Canada.
We may need to disclose Personal Information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with our Company’s rights or property, other users of our Sites and Services, or anyone else that could be harmed by such activities.
As you interact with our Sites and Services, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of this Site and our Services and collects certain other information about your visits and habits. This data collection technology may include cookies, web beacons and other similar devices which is used to enhance functionality and navigation for our visitors and to provide customized experiences.
A cookie is a small data file that is placed on the hard drive of your computer or your mobile device to “remember” information when you visit a webpage.
Web beacons and tags are small strings of code that are used in conjunction with a cookie and allow us to record activity on our Sites. Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular webpage. We may use web beacons on our Sites to recognize users by accessing our cookies, so that we are able to personalize our Sites and Services and improve your experience.
We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages are opened. Information tracked through these mechanisms includes, but is not limited to your IP address, the type of web browser and operating system being used, our Sites’ webpages that you visit, and websites or other sources where you may have clicked links to arrive at our Sites and Services.
We may also employ cookies and action tags (also known as single pixel gifs or web beacons) to collect information about your use of, and activities on, our Sites and Services for our use and also for use by Third Parties that serve advertisements about our Company on other webpages or services that you may visit. In addition to the information about your visits to our Sites, Third Parties may also use the information about your visits to other sites to provide advertisements for services available from us.
Most internet browsers are initially setup to receive cookies. At any time, you can adjust your internet browser(s) settings so that you:
If you do not accept cookies, you may be restricted in how you are able to use our Sites and Services. You can delete cookies that are already stored on your computer or mobile device at any time. You will find more details on how to do this in the operating guides for your internet browser programs.
And example of cookies we may employ on our Sites and Services:
Cookie Name Purpose
kjb_session Session cookie Tracks your session to recall upon your next visit
kjba Affiliate token Tracks which affiliate has referred an offer purchase
_abv Admin bar hidden Tracks whether a user wishes an admin previewing bar to be hidden
Third Party Analytics
Additionally, Google may transfer this information to a third party when required by law or in the case of a Third Party processing information on Google's behalf. In no case will Google use your IP address in connection with any other information held by Google.
By using our Site, you consent to the processing of data about you collected by Google LLC in the manner described and for the above-mentioned purpose.
Your consent for collection and storage of data can be withdrawn at any time by clicking on the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
We also use the analytics we obtain to carry out assessment on site visit frequency, webpage usage and marketing. For these assessments, we collect and use these analytics in aggregate form which cannot be reasonably manipulated to identify any particular individual.
Neither our Company nor our Sites and Services knowingly permit the use of malware, spyware, viruses, and/or other similar types of malicious software.
You may request access to your Personal Information which we may hold by contacting us at the contact information below and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the Personal Information we hold about you. There is no cost for such access request unless you require copies of records.
We may not be able to provide you with access to your Personal Information if the information cannot be separated from the Personal Information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your Personal Information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.
You may also request to update and change your Personal Information which we may hold by contacting us at the contact information below. We will endeavor to correct or complete any Personal Information which you advise us is inaccurate or incomplete. Where appropriate, the amended information will be transmitted to Third Parties having access to such information.
At any time, you may request that we delete your account or membership on our Sites or Services by contacting us at the contact information below with a heading “Delete Account”.
As part of accessing our Sites or registering or becoming members to receive our Services, you may have also chosen to receive email communications from us. If you opted-in to receive such communications, we send you information and promotions regarding our Sites and Services, events, articles and other information that may be of interest to you, as well as, other information that you request or that notifies you of improvements to our Sites and Services.
If at any time you no longer wish to receive future e-mails from us, you will have the opportunity to opt-out from receiving ongoing communications. We will include instructions in our emails for how to "unsubscribe" from an email list. If you are unsuccessful in completing the instructions specified in any such communication, please contact us at the contact information below and state your wish to be removed from an email list.
We maintain technological, organizational, and physical security safeguards to protect your Personal Information against loss, theft, and unauthorized access. Any Personal Information that you provide to us is exchanged on secured servers. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your Personal Information, we cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to us, you accept that you do so at your own risk.
We take reasonable steps to verify your identity before granting you access to your account on our Sites and Services, however, you are solely responsible for maintaining the secrecy of your username, password and any other account information, as applicable.
We also take reasonable steps to ensure that our employees are aware of the importance of maintaining the confidentiality of Personal Information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.
We are committed to protecting the privacy of children and we do not knowingly solicit personal information from children under the age of 13. If a child has already provided us with personal information, their parent or guardian may contact us at the contact information below for the purpose of deleting this information.
Our Site: https://www.dramy.life/contact
Mail: Life Transitions by Dr. Amy, Inc.
Attn: Privacy Officer
26 Cavell Ave.
Toronto, ON M4K 1L6
Information provided by you, such as your name and email address, will be used to respond to your inquiries in the ordinary course of business, and will not be shared with Third Parties, unless necessary to your request.