Pasela Privacy Policy

Last updated January 09, 2024

We are Positive Action, Inc. (“Positive Action”, “we” or “us”), an Idaho corporation with a registered office located at 264 4th Ave S, Twin Falls, Idaho 83301.

We operate the website https://www.pasela.com (the "Site"), as well as any other related products and services that refer or link to these legal terms (the "legal terms") (collectively, the "Services"). Pasela is a web app designed to deliver instructional content from Positive Action, Inc.

Our priority is to educate and make it easy for customers to understand what data we collect, why we collect it, and how we use it.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the Site, and describes our practices for collecting, using, maintaining, and protecting that information. Please read this Privacy Policy carefully to undeΩrstand our policies and practices regarding your information and how we will treat it.

By accessing or using the Site, you agree to this Privacy Policy. If you do not agree with our policies and practices, please do not use the Site or any Services available on or through the Site.

We recommend that you print a copy of this Privacy Policy for your records.

Protecting Your Privacy

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

We maintain administrative, technical and physical safeguards designed to assist us in protecting the personal information we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We also maintain our own server equipment which is located in a secure facility that features controlled access and preventive security measures. Only authorized Positive Action personnel and agents can access the equipment or data.

We have also encrypted network traffic between our equipment and yours with a 2048-bit secure socket layer certificate issued by a reputable authority. This theoretically provides basic protection from eavesdropping and other forms of surveillance.

Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.

Information You Provide

We will ask you when we need information that personally identifies you or allows us to contact you including (but not limited to): your name, e-mail address, postal address, date of birth, and URL (collectively, “Personal Information”). Generally, this information is requested when you contact us for information, place an order for our products or services, or when you complete a survey.

We use your Personal Information for the following primary purposes:

  • To make our Site easier for you to use by not having to enter information more than once.
  • To help you quickly find information on the Site.
  • To alert you to special offers, updated information and other services from our company, affiliates, and business partners.

What kinds of information and data do we collect?

We may ask for certain personal data to make our services available to you. We only ask for information associated with your account or the administration. When ordering or registering on our Site, as appropriate, you may be asked to enter contact information and credit card information. You may, however, visit our Site anonymously. We will retain your personal data only for as long as is necessary for the purposes detailed in this Privacy Policy.

We may collect information about you from various sources, including when you request or enter information on the Site or otherwise use the Site, and when you contact us by email or other means. Such information may include information by which you may be personally identified, such as your name, postal address, email address, and telephone number (“personal information”), and other information as described in this Privacy Policy.

Among other things, we may collect the following information:

  • Name
  • Job title and employer
  • Contact information including email address and postal address

We will also ask for payment and business information for invoicing purposes, although this information is received and processed by a third-party payment processor (the “Processor”), and Positive Action never receives or records this information. Positive Action is not responsible for the handling of this information by such third-party Processor, and you should review the Processor's terms and privacy policy before sharing any payment information with them.

Purchases and payments may be facilitated through third-party Processors such as Chargebee.com or Stripe.com. Please refer to their respective websites for more information.

In addition, the Site collects personal data through web form submissions, primarily for the purpose of enabling the purchase of Services and engaging in support. Positive Action also collects anonymous information about how visitors use our web Site; for example, Positive Action utilizes web analytics software to track, in aggregate, the number of unique views received by the pages of the web Site, the domains from which users originate along with many other analytical data points. Through the use of web analytics software, the Positive Action Site may use "cookies" to assist the tracking of how users engage our website.

The Site will also automatically gather and store in log files information such as: IP addresses, browser types, ISPs, referring/exit pages, operating systems, date/time stamps, and movements around the Site. The Site also gathers demographic information and other information from you based on your responses to surveys and similar Site services. At no time will Positive Action require a child to disclose more information than is reasonably necessary in an activity as a condition of participation.

We do analyze website functionality for performance for purposes of improving our service offerings to our customers.

You understand that you shall be solely responsible for the accuracy and truthfulness of the Personal Information shared with us. In the event you share any Personal Information on behalf of a third person, you shall ensure that you have the necessary authority to share such Personal Information with us.

How we Collect Information. Positive Action may collect information from you in several different ways including the following:

Requests

When you request information from us, by phone or e-mail, through the Site, or by requesting to join our mailing list, we may collect certain personally identifiable information from you. If you respond to a survey or sign up contest or drawing, we may request certain Personal Information. We use this information to provide you with information, customer service, or other services related to your request.

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and movements around the Site, and to gather demographic information about our user base as a whole. We do not link this automatically collected data to personally identifiable information.

Correspondence

If you send us personal correspondence, such as an email or letter, we may collect such information into a file specific to you.

Third Party Referral

We may collect certain personally identifiable information regarding you, when a third party may voluntarily provide such information, in particular when using the “Share this” option present on parts of the service.

Public/Sponsored Events

Positive Action participates in many public events and events with multiple sponsors, such as trade shows and seminars. The events generally collect certain personally identifiable information from all attendees and distribute this data in whole or in part to all the event sponsors including Positive Action. While we cannot control and are not responsible for the practices of other sponsors for these events, Positive Action will maintain the privacy of its copy of your Personal Information received in this way.

Links

The Site may contain links to other sites. However, please be aware that Positive Action is not responsible for and cannot control the privacy policies of such other sites. We encourage you to be aware when you leave the Site, and to read the privacy policies of each and every web site that collects personally identifiable information. This Privacy Policy applies solely to information collected by the Positive Action Site.

Site Usage

Positive Action may monitor your activities, preferences, and transactional data (such as your IP address) relating to your use of the Site and/or services and log this information. This information may be used to diagnose Site technical problems. We also use personal and non-Personal Information in aggregate or statistical form in order to improve our products, services and procedures. This means that information from many persons and/or web Site visits is grouped together in a way that does not disclose the Personal Information of any particular person. For example, we track how many people have expressed interest in a particular product and what kinds of web browsers are most often used when visiting our web Site. Among other things, this information helps us determine which of our products and services are successful and which should be changed or discontinued.

Customer Service

Based upon the personally identifiable information you provide us, we may send you a confirmation e-mail to act as a receipt of your purchase. We will also communicate with you in response to your inquiries and to provide the services you request.

Business Services

We will also communicate with you in connection with services you request from Positive Action.

EU General Data Protection Regulation

For residents of the EU, please note that this Privacy Policy has been drafted in accordance with the requirements of the EU General Data Protection Regulation (GDPR).

California Online Privacy Protection Act Compliance

Because we value your privacy, we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.

Who is collecting the data?

Positive Action and collaborating third parties in order to provide service to our users.

Our Legal Basis for Collecting Data

We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal bases of consent [as provided in Art. 6 (1) (a) of the GDPR], contract [as provided in Art. 6 (1) (b) of the GDPR], or on the basis of our legitimate interests [as provided in Art. 6 (1) (f) of the GDPR], provided that such interests are not overridden by your privacy rights and interests.

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information when you place an order.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems and are required to keep the information confidential.

After a transaction, your private information (credit cards, financials, etc.) will not be stored on our servers.

Positive Action is committed to ensuring that your ordering information, including your customer information, is protected while you are on the Site. Positive Action uses appropriate and reasonable measures to maintain the security of your Personal Information. This includes procedures followed by our personnel to prevent data loss or theft, physical security of our servers and information stores and electronic security such as firewalls, password-protected databases and secure connections.

Positive Action may use certain third parties for services such as advertising, marketing and order fulfillment. We only work with third parties whose privacy policies and security practices are equal to or more stringent than our own and who agree to strictly limit their use of the information we provide them to fulfill the functions for which they have been retained. You should be aware, however, that no data transmitted over the Internet, sent through the mail or stored on a computer is 100% secure and that we cannot guarantee the security of your personal data while in transmission to us. Public computers in particular should never be considered secure.

You should never give out Personal Information on the Site, or its message board, in chat rooms and other publicly viewable locations. In addition, there exist malicious programs, typically called computer viruses or trojan horses, which can be used to capture information off your computer's hard drive or while you are entering it into a web form or sending it by email. You should always use the appropriate anti-virus and personal security technology to protect yourself.

Lastly, if you have been assigned a login ID and/or password for use on an Positive Action system (for example, a login for our web store to purchase products), you should never give out that information to others.

Disclosure of Collected Information

Information from the Site. Positive Action will never disclose to non-affiliated third parties without your prior approval your e-mail address, phone number, or other Personal Information that we collect via the Site. However, we reserve the right to outsource certain activities to certain third parties. In such cases, we strictly limit the information provided to these third parties to the minimum necessary for them to perform the functions for which we have retained them and prohibit them from using the information for any other purpose or retaining it after it is no longer needed.

Law Enforcement

Positive Action, however, will cooperate with official law enforcement inquiries, such as fraud investigations and subpoenas, and will disclose your information when necessary to comply with state and federal laws and regulations.

Disclaimer

We cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose Personal Information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmission or private communications, or users may abuse or misuse your Personal Information that they collect from the Site.

Children 18 Years of Age and Younger

You must be 18 or over to use the Site. We are in compliance with the requirements of COPPA (Children's Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.

Your Rights Regarding the Date We Collect

With respect to the data we collect from you, you have the following rights:

  • the right to be informed about the data we collect;
  • the right to access and review the data we have collected from you;
  • the right of rectification or correction of any data we have collected from you;
  • the right to have any/all data we collect removed;
  • the right to restrict how we process data we collect from you;
  • the right to data portability;
  • the right to object to our collection of data; and
  • the right to prevent direct marketing, automated decision-making and profiling.

Correcting or Removing Data

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Moreover, if you wish to take advantage of any of the above rights, please contact us and we will comply at no charge to you. To review, request a copy of, or delete your account information you may contact us via e-mail at: info@positiveaction.net.

Our Data Retention Period

We typically maintain your data for as long as you use our Site and/or our services. We also reserve the right to retain any/all data from our users and former users indefinitely unless/until the user requests deletion of their data, or in the event we are legally required to remove the data, whichever occurs first.

We will generally only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under this section above. However, in the following circumstances, we may be required to retain, preserve or disclose your Personal Information for a longer period of time:

  • in order to comply with applicable laws or regulations;
  • in order to comply with a court order, subpoena or other legal process;
  • in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere);
  • where we believe it is reasonably necessary to comply with applicable laws or regulations; or
  • in order to enforce the Positive Action Terms of Service or this Privacy Policy, protect our rights, property or safety, or the rights, property, or safety of our affiliate companies or other users of Positive Action.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Provide products and Services to you.
  • Improve our products and Services.

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others' rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Positive Action uses the collected Personal Data to provide and maintain our Services and provide customer support for our Services. Positive Action will only use your Personal Data to provide you with news, special offers or general information only if you have willingly Opted In to receive such information.

Positive Action may collect and use your Personal Information for the following purposes:

Providing and improving our products

We are able to deliver our Services, personalize content and make suggestions for you by using this information to understand how you use and interact with our Services and the people or things you're connected to and interested in on and off our Services. We also use information we have to provide shortcuts and suggestions to you. When we have location information, we use it to tailor our Services for you and others, such as helping you check in and find local events in your area or telling your friends that you are nearby. We conduct surveys and research, test features in development and analyze the information that we have in order to evaluate and improve products and services, develop new products or features and conduct audits and troubleshooting activities.

To process transaactions

Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.

Promoting safety and security

We use the information we have to help verify accounts and activity, and to promote safety and security on and off our Services, such as by investigating suspicious activity or violations of our terms or policies.

Communicating with you

We use your information to send you marketing communications, communicate with you about our Services and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Sending emails or pushing notifications

We may occasionally also send emails such as company news, updates, related product or service information, etc., and we will use your basic Personal Information to respond to inquiries, questions, and/or other requests. We may also use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties. You may at any time change your preferences or turn off notifications, which will alter or cease the specific notifications you receive. You may also cancel your account at any time, in which case we will cease sending you reminder emails, but you may continue getting shared content from others until you specifically turn off those notifications. We may use a third-party mailing list service for company announcements or occasional marketing emails, and you may need to unsubscribe from these emails separately than other types of emails.

Cookies Policy

Cookies are small data files that are placed on your device when you visit our website. We use Cookies to improve your experience on our website and to provide you with personalized content and advertising. Cookies provide data to monitor the performance of our website and understand traffic patterns, ultimately enabling us to improve your browsing experience. This page explains what Cookies we use, how we use them, and how you can manage them.

We use the following types of Cookies:

Essential Cookies: These Cookies are necessary for the website to function properly and cannot be disabled in our systems. They are usually set in response to actions made by you, such as setting your privacy preferences or filling in forms.

Performance Cookies: These Cookies allow us to analyze how visitors use our website and to improve its performance. For example, they help us to identify which pages are popular and which ones need improvement.

Functional Cookies: These Cookies allow us to analyze how visitors use our website and to improve its performance. For example, they help us to identify which pages are popular and which ones need improvement.

We use Cookies to:

  • Remember your preferences and settings.
  • Improve our website performance.
  • Monitor traffic and analyze usage patterns.
  • Prevent fraudulent activity.

How To Manage Cookies:

You can manage Cookies by adjusting your browser settings. Most browsers allow you to block or delete Cookies. However, please note that disabling Cookies may affect your ability to use certain features of our website.

To manage Cookies in your browser:

  • Google Chrome: Click the three dots in the top right corner, select "Settings," and then click "Privacy and security." Under "Cookies and other site data," select "Block third-party Cookies."
  • Mozilla Firefox: Click the three lines in the top right corner, select "Options," and then click "Privacy & Security." Under "Cookies and Site Data," select "Block Cookies and site data."
  • Apple Safari: Click "Safari" in the top left corner, select "Preferences," and then click "Privacy." Under "Cookies and website data," select "Block all Cookies."
  • Microsoft Edge: Click the three dots in the top right corner, select "Settings," and then click "Privacy, search, and services." Under "Cookies and site permissions," select "Block all Cookies."

Each of these browsers also support a “Do Not Track” function. Our first party Cookies are designed to respect this functionality. We cannot ensure that third party cookies will respect this functionality.

The table below lists what information our first party Cookies store:

  • User IP address
  • User ID
  • Date and time of the request
  • Title of the page being viewed (Page Title)
  • URL of the page being viewed (Page URL)
  • URL of the page that was viewed prior to the current page (Referrer URL)
  • Screen resolution being used
  • Time in local user's time zone
  • Files that were clicked and downloaded (Download)
  • Links to an outside domain that were clicked (Outlink)
  • Pages generation time (the time it takes for webpages to be generated by server technology and then downloaded by the user: Page speed)
  • Location of the user: country, region, city, approximate latitude and longitude (Geolocation)
  • Main language of the browser being used (Accept-Language header)
  • User Agent of the browser being used (User-Agent header)
  • Random unique Visitor ID
  • Time of the first visit for this user
  • Time of the previous visit for this user
  • Number of visits for this user

Web Beacons

Web beacons are very small, invisible graphics present on our emails. Positive Action uses web beacons to track when an email has been accessed.

Enforcement

If for some reason you believe Positive Action has not adhered to the principles of this Privacy Policy, please notify us, and we will do our best to determine and correct the problem promptly.

Disputes

This Privacy Policy shall be interpreted and governed by the laws of the United States and the State of Texas without regard to conflicts of laws. Any dispute arising out of this Privacy Policy shall be settled by final and binding arbitration conducted in Dallas, Texas, by one neutral arbitrator knowledgeable in the subject matter covered by this Privacy Policy, in accordance with this Section and the then current Commercial Arbitration Rules of the American Arbitration Association (“AAA”). The successful party in the arbitration shall be awarded by the arbitrator that party's costs and expenses, including attorneys' fees and administrative fees of the AAA. An award may be confirmed and judgment entered in any court having competent jurisdiction. Except as otherwise provided for herein, any litigation initiated under such act or otherwise shall be conducted in a court of competent jurisdiction located in Dallas County, Texas.

Notification of Privacy Policy Changes

We reserve the right to change this Privacy Policy at any time, and you may visit this page to learn of our revised Privacy Policy. All such changes shall be binding on you 14 calendar days after they are initially posted on the Website unless you are a new user, in which case they are binding on you immediately.

Business Transition

In the event we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personally identifiable information will likely be among the assets transferred.

Representations and Warranties

By using this Site, you represent that you are seeking this Site for personal reasons and that you are not an attorney or an agent of an attorney conducting an investigation to a potential claim related to the Site, any material available through the Site, or Positive Action. You also represent that you are not engaging in activities in an attempt to reverse engineer the Site, portions of the Site, or any materials available through the Site. You also represent that any information you provide is true and accurate.

Customer Reference

You agree (i) that Positive Action may identify you as a recipient of services and use your logo in client lists, sales presentations, marketing materials and press releases, and (ii) to develop a customer profile for use by Positive Action on Positive Action websites for promotional purposes.

Notices

Any notices or other communication required or permitted to be made or given by either Party pursuant to this Privacy Policy will be in writing, in English, and will be deemed to have been duly given when delivered if delivered to the address specified herein or such other address as Positive Action may specify in writing. All notices must be sent to or via email to: info@positiveaction.net.

If you have any questions or suggestions regarding our privacy policy, please contact us through the Contact Us section of the Site, or via email to: info@positiveaction.net.

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