INTRODUCTION

The following Privacy Policy governs the online information collection practices of Evolve Restorative Therapy d/b/a “livepainfreeprocess.com” (“we” or “us”). Specifically, it outlines the types of information that we gather about you while you are using the sohp.com website (the “Site”), and the ways in which we use this information. This Privacy Policy, including our children’s privacy statement, does not apply to any information you may provide to us or that we may collect offline and/or through other means (for example, at a live event, via telephone, in office or through the mail).

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy. Because the Web is an evolving medium, we may need to change our Privacy Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on this website and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Site after we post any such changes, you accept the Privacy Policy as modified.

Your privacy and safety on the Internet are of the utmost importance to me. I want to ensure that your online experience with me is satisfying and comfortable.

I work very hard to create a safe environment for all my web visitors. And to my best understanding of the law, go out of my way to adhere to US & international laws and best-practices of the web. I also uphold the oldest universal law of them all, “The Golden Rule”. Because I gather certain information on this site, I feel you should fully understand my policy and the terms and conditions surrounding the capture and use of that information. This privacy statement discloses what information I gather and how I use it. This document has been written in a very simple readable format for you, so that you will be able to understand exactly what I am doing to ensure you can take a deep breath, relax,  have fun and are safe every time you visit my site.

HOW WE COLLECT AND USE INFORMATION

We may process the following categories of personal data about you:

* Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Some examples include:

Blogs and Forums: We may provide an opportunity for you to post information to blogs, forums or other public areas on the Services. By doing so, you consent to the posting of any Personal Information that you provide. You should be aware that such Personal Information can be read, collected, or used by other visitors to these public areas. We have no control over how these visitors use your Personal Information.

Inquiries. If you send us a comment or question or make an inquiry to customer support, we will retain the information that you provide to us for the purpose of responding to you, as well as for improving the Services and our customers’ use of our services.

* Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

Some examples include:

Registration: When you register on the Services, such as to subscribe to a newsletter, request information or access a Product, you will be asked to provide certain Personal Information, which we will use to fulfill your request.

Surveys: We may ask you to complete surveys or opinion polls from time to time. We only use the information that we collect from surveys in an aggregate manner, not in individually identifiable form. We may use specific comments shared on surveys, in an anonymized way. We may also reach out for more clarification on survey responses and potentially request more and permission to share. But we will never share anything personally identifiable shared on a survey unless given consent.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain backups of our website and/or databases and to enable publication and administration of our website, other online services, and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Some examples include:

Web Logs: We maintain web logs that automatically record basic information about everyone who visits the Services. We use web log information to help us design our website, to identify popular features, to improve our services, and for other managerial and analytic purposes. We may also use web logs to help identify any person who may be misusing the Services. These logs contain:

• The Internet domain from which you access the Services.
• Your IP address.
• The type of browser and operating system that you use.
• The date and time you visited the Services.
• The pages that you visited on the Services.
• The address of the website you linked from to get to the Services.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

More specifically, here are some examples:

Linking from Emails. If you click a link to any of our Sites from an email message from us, we will be able to identify your email address and associate that email address with the manner in which you use the Sites (e.g., which pages you visit or whether you make a purchase).

Visitors: If you are just visiting the Sites and not registering, requesting information, contacting us, or posting to a public area of the Services, and you did not access the Sites from a link contained in one of our email communications, we will not ordinarily collect any Personal Information about you except through web logs, as described below. In that case, we obtain the information that you provided and will use it to respond to your inquiry or fulfill your request if we can. We do not share any of this information with anyone else, except to respond to your request, if you consent, or as otherwise described in this privacy policy.

Web Logs: We maintain web logs that automatically record basic information about everyone who visits the Services. We use web log information to help us design our website, to identify popular features, to improve our services, and for other managerial and analytic purposes. We may also use web logs to help identify any person who may be misusing the Services. These logs contain:

• The Internet domain from which you access the Services.
• Your IP address.
• The type of browser and operating system that you use.
• The date and time you visited the Services.
• The pages that you visited on the Services.
• The address of the website you linked from to get to the

How I Use Surveys:

Most surveys ask for personal contact information, information about your business, and  how you operate it. You may choose NOT to respond to any survey. All surveys are optional. However, some of my content may be inaccessible to you if you choose to exercise your right to not respond to a survey or omit any of its “required” fields. I maintain the right to use information I collect to assist with the research and development of course materials, new products, training, and other promotional content that will best serve my readers and subscribers. I will never give access or sell any of your information to others not employed by me. However, keep in mind that I do use 3rd party software services to store and maintain client information such as SurveyMonkey.com and AWeber.com (they provide the autoresponder & contact management services most online businesses need).

How I Use Your E-Mail and Phone Number:

Rest assured that your email address or phone number, if I ever ask for them, will only be used by ME to communicate with you. Since I am a business owner, it is not possible to always handout FREE, super high quality, truly helpful information by email—without offering something for sale. I feel no shame in admitting that a great deal of the “free” information I send will be a value-driven demonstration or preview of my services and/or products that I want you to feel comfortable buying from me. You always have the option of not buying anything at all from me. And I encourage you to use all of  my best free training, tips, and tools to learn a lot of the things that will help you live a pain-free life. In fact, you may just prefer to benefit from our promotional materials and never pay a cent for anything. And that is perfectly ok with me. I am here to serve and to help as many people as I possibly can.

To help cover my costs, however, I do often run promotions and send out emails about products available from certain trusted partners that I personally use in the operation of my business. I do this to help you diversify your education, improve the quality of the tools and systems that you need to run your business and to make money when you purchase something that I recommend. I am a red, white and blue capitalist through and through. I strive to make even the promotional emails entertaining and useful to my subscribers whether or not they choose to take me up on the offer. Emails and updates are TYPICALLY sent out 4-5 times a week. However, during promotions you may receive, for example, two emails from me in a single day. I reserve the right to choose how frequently I email as long as I allow my subscribers to choose whether or not they want to hear from me.

Third Party Contact Management Software:

I never share any of this information with third parties, except those that collect the information for me such as AWeber (contact management system) and paypal (payment management system). These third party services do not contact you. They are business tools that make it easier for me to manage contacts and finances. It is normal for most businesses on the internet to use these exact services because they add another layer of protection for you. For example, I never SEE information you use for making purchases. Instead, I employ the use of a 3rd party payment processor such as Paypal. Paypal has much higher security than I have available in my server’s hardware setup, and this is why I use them. You can tell you are protected by standard secure technologies (SSL) wherever you see the “https” protocol in the address bar provided the current security certificate is valid. Paypal also protects you should you have issue with me and feel the need to complain. Processing services help you claim refunds or request disputes if necessary. While I strive to handle ALL customer issues myself to keep you happy, I understand that having a 3rd party to arbitrate between us makes things easier sometimes from a legal standpoint. What you need to know is that I never see, handle, or store any payment or password information. Instead I leave this in the hands of professionals who have all the necessary securities so you can buy from me feeling safe and secure.

Tracking Technologies:

Cookies: We use cookies, web beacons and similar technology to help you navigate the Services, to allow us to learn how you use the Services, and to improve the Services. Cookies are text files we place in your computer’s browser to store your preferences. Cookies, by themselves, do not reveal any Personal Information unless you choose to provide this information to us by, for example, registering at our Site. However, once you choose to provide Personal Information to the Services, this information may be linked to the data stored in the cookie. If you decide not to permit cookies on your computer, this may affect your ability to use the Services.

* We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at pamela.gail.sohp@gmail.com and please use the subject line: “Data Request.” In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.

HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this: LIVE PAIN-FREE PROCESS Cookie Policy

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

I am an offline and online marketer. I always study and track the effectiveness of every aspect of my website to maximize ROI. Because of this, cookies are used throughout my websites. Cookies are a standard means for internet businesses to store and later retrieve “temporary preferences” specific to one computer. Cookies are ALWAYS stored on your own computer in your browser (no one else can access info stored in cookies except yourself and the actual website that created the cookie). Not all Internet browsers store cookies, but most do. You can turn the option off in your own browser if you prefer and this will let you reject all cookie requests from this site in the future. While this decreases the functionality of my site, it is your choice to make. My website uses cookie technology extensively to increase my ROI. Here is more detailed information:

General:

Various 3rd party tracking technologies allow me to use cookies in a way to tell whether or not visitors to my site notice new additions, whether or not they click on links that make me money, and how frequently (and which language) sells my offer best.

Tracking on My Websites:

Some of the technologies I use are Google’s Conversion Optimizer, Yahoo Conversion Tracking, and Google Analytics. These services provide me with anonymous data about visitor activity on my website and allow me to study the cost of acquiring customers with various offers. I can also tell things like which  internet browsers are most popular for browsing our website and which screen resolutions the majority of our visitors use. I am also able to measure other general data that helps me create a better experience for future visitors and loyal returning visitors. If you don’t want to be tracked, you may turn off ALL tracking by disallowing cookies when browsing my website.

Tracking in My Emails:

I also track how often emails are opened and whether or not links inside them are clicked. Not all of this activity can be tracked, and it depends on what email client you use and which settings you chose in your email client. This tracking can be turned off from your email client if you rather not contribute to our statistics.

Easy tip to switch off tracking ===>>> Turn off HTML emails and only receive text. We can’t tell if that email is opened. Avoid clicking links if you don’t want me to count your click. All links in email are automatically tagged by my email service (not me) with a click-counter.

Note, I always comply with ICAN email standards. Everyone that I email is a double opt-in subscriber, meaning that you personally had to respond to a confirmation email in order to be added to my list. ICAN’s extensive anti-spam rules say that I cannot email anyone unless they have specifically opted-in and requested contact from me. I use a 3rd party service,  AWeber, which ensures strict adherence to those standards (even when I don’t know them in detail) and they prohibit me from sending spam or using any blackhat or illegal email practices. My websites have excellent track-records and have been using services like AWeber and PayPal without complaints for many years. Part of the ICAN standard requires me to allow subscribers to easily remove themselves from my email list any time they want to stop receiving emails from me.  Madness I know … but it does happen. And I really don’t want to bother you if you don’t want my emails. So every single email communication from this website has a link at the bottom allowing you to stop hearing from me at ANY time. Use it, I promise, I won’t get mad.

MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by clicking the 1-click unsubscribe button at the bottom of our emails or by sending us an email at pamela.gail.sohp@gmail.com.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

How We Use Your Information

Here is how we may use your information and data:

Communicating with You. We may use information that we collect from you for the purpose of communicating with you and responding to your inquiries. Those communications could, for example, take the form of service updates, promotions for products or services that we or one of our marketing partners provide, or e-newsletters.

Service Providers: We at times contract with third party service providers to perform functions for us. These service providers may be given access to the information we collect for the purpose of performing those functions, but they will be contractually bound to maintain the confidentiality of the information and not to use it for any other purpose.

Social Media. The Sites may include social media features, such as Facebook “Like” button and a “Share” button. These features may collect your IP address and which page you are visiting on the Site, and they may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company that provides the feature.

Business Transfers: If we were to transfer all or substantially all of our assets to another company, one of the assets we would likely include in the transfer is our database of Personal Information.

Disclosures for Legal Reasons: We will disclose Personal Information when we are required to do so by law, regulation or securities exchange requirement, for example, in response to a court order or subpoena. We also may disclose such information in response to a law enforcement agency’s request or when we believe such disclosure is appropriate to protect our legal rights or to safeguard anyone’s property or safety.

How We Share Information – And Why

We may have to share your personal data with the parties set out below:

* Other companies in our group who provide services to us.

* Other companies in our group who provide services to us.

* Professional advisers including lawyers, bankers, auditors and insurers

* Government bodies that require us to report processing activities

* With third-party advertising platforms so that we can create marketing campaign advertising (e.g. using your email address to create a Facebook targeting audience).

* When you participate in an interactive area of our website, service, and products, and your information may be displayed to other users: such information may include, your name, photo, the comment, and other information you chose to provide at the time of submission. In the case of Surveys, we will never share personally identifiable information without express consent.

* In response to a request for information if we believe disclosure is in accordance with or required by, any applicable law, regulation or legal process;

* If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Company or others;

* Third parties to whom we sell, transfer, or merge parts of our business or our assets.

* With your consent or at your direction.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

* We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

* If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or

* Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at patrick@livepainfreeprocess.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see LIVE PAIN-FREE PROCESS Cookie Policy

COLLECTION OF INFORMATION BY THIRD PARTIES

We may use a third-party advertising company to serve ads when you visit our Site. If we do so, this company may use information (not including your name, address, email address or telephone number) about your visit to the Services in order to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements to the Services, the advertiser might place or recognize a unique “cookie” on your browser.

We may offer you the opportunity to contact other companies, such as advertisers, marketing affiliates and content providers, to obtain information or to buy products or services. You decide when and whether to give your Personal Information to these companies. If you provide information, its use and security is governed by the policies and practices of those companies and not by this privacy policy.

We make no representations or warranties about any of these other companies or their privacy or security policies. Once you click through to an unaffiliated website, this privacy policy no longer applies. We strongly urge you to read the applicable policies of these other companies and their websites.

4. YOUR PRIVACY CHOICES

If you would like us to stop sending you email or other communications or would like to access your Personal Information to correct or delete it, you may send us a request at our email indicated below. We will endeavor to satisfy such requests within a reasonable time.

patrick@livepainfreeprocess.com

5. DO NOT TRACK

There will be no difference in how we collect or use data if you set your web browser to send a “Do not track” or similar request when you visit this Site.

6. LINKS

Our Site includes links to other websites whose privacy practices differ from ours. If you submit personal information to any of those websites, your information will be subject to their practices and policies.

7. SECURITY

We maintain all Personal Information with physical, electronic, and managerial safeguards to help ensure the security and confidentiality of the data against reasonably foreseeable risks. Security is designed to prevent unauthorized use, access, disclosure, destruction, and changes of data.

8. CHILDREN

This Site is intended for use by adults. We do not target, or knowingly collect any Personal Information from, children under the age of 13.

9. ACCOUNTABILITY

We are committed to adhering to our privacy policy and applicable laws and to making your online experience secure and valuable. If you have a question, request, complaint, dispute or concern related to this privacy policy, you may send a message by email to patrick@livepainfreeprocess.com. We will work with you to obtain a prompt resolution of any issues you may have.

If you choose to use the Postal Service, I can be contacted at:

P.O.BOX 281
GARWOOD NEW JERSEY 07027
USA