PRIVACY POLICY

Soul in the Raw

Last Modified: June 14, 2023

Marina Yinay-Triner DBA “Soul in the Raw” (“we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this “Privacy Notice.” Throughout this Privacy Notice, we refer to any person accessing or using these Websites (as defined below) as “you” or “user.”

This Privacy Notice describes the types of information we may collect from you or that you may provide when you visit the websites www.marinayt.com and www.marinayanaytriner.teachable.com, the services, features, and content offered by Soul in the Raw (collectively our “Websites”) and our practices for collecting, using, maintaining, protecting and disclosing that information. 

We take your privacy very seriously. Please read this Privacy Notice carefully as it contains important information about how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

1. Children Under the Age of 13. Our Websites are not intended for children under 13 years of age. No one under the age of 13 may provide any personal information to Soul in the Raw or through the Websites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through any of the Websites’ features/functionality, make any purchases through the Websites, use any of the interactive features that may be available on these Websites, or provide any information about yourself to us, including your name, address, telephone number, and/or email address. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@marinayt.com. 
2. personal information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household: Name, signature, postal address, telephone number, usernames or online identifiers, Internet Protocol address, email address, credit card number, debit card number, or any other financial information, browsing history, search history, information regarding a user’s interaction with the websites.
   

This personal information is required to provide our products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing those products and services to you.

We may also collect information that is about you but individually does not identify you, such as your sex/gender (which may include pregnancy, childbirth, and related medical conditions), age/date of birth, or marital status. This information is not considered personal information, as it is anonymized, statistical data. 

3. How Your personal information is Collected.

Information We Collect Automatically

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your devices, browsing actions and patterns, as described above. The technologies we use for this automatic data collection may include cookies, flash cookies, or web beacons. The technologies we use for automatic data collection on these Websites may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites;
• Flash Cookies. Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies; and/or
• Web Beacons. Pages of the Websites, and our emails, may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit Soul in the Raw, for example, to count Users who have visited those pages, or opened an email, and for other related statistics (for example, recording the popularity of certain content on the Websites and verifying system and server integrity). 

The information we collect automatically is statistical data and does not include personal information, but we may maintain it for any of the reasons described herein.

Information You Provide Directly to Us

The information we collect on or through our Websites may include:

• Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites or signing up for our mailing list. We may also ask you for information  when you report a problem with our Websites;
• Records and copies of your correspondence (including email addresses), if you contact us;
• Details of transactions you carry out through our Websites; and/or
• Your search queries on or through the Websites.

Information Provided to Us by Third Parties

If we receive information about you from a third party (for example, any business partners), we will protect it as set out in this Privacy Notice. If you are a third party providing information about somebody else, you represent and warrant that you have such person’s consent to provide the information to us.

4. Third Party Use of Cookies and Other Tracking Technologies. Some content or applications on the Websites are served by third-parties, including content providers and application providers. These third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Websites. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.  

5. Why We Use Your personal information. We only use your personal information if we have a proper reason for doing so. For example:

• To enable you to access and use our Websites;
• For the performance of our agreements with you or to take steps at your request before entering into an agreements;
• To contact and communicate with you;
• To prevent fraud;
• For internal record keeping and administrative purposes;
• For analytics, market research, and business development, including to operate and improve our Websites;
• To offer additional benefits to you, including but not limited to sending promotional information about our products/services and/or facilitating competitions and/or giveaways;
• To comply with our legal and regulatory obligations;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

Type of Data Collected	Source of Data	Basis/Bases for Processing	Who We Share This Data With
Personal contact information, such as your name, postal address, email address, phone number.	Directly from you; from cookies and similar automatic technologies; from third-party sites or apps, content distribution channels and platforms; from third-party business partners; and from social media platforms and similar services.	To perform our contractual obligations to you; to pursue our legitimate interests; to comply with our legal obligations; with your consent.	With service providers and/or business partners; with professional advisors or legal counsel; with government authorities as required by law or as necessary to protect our rights.
Demographic information.	Directly from you; from cookies and similar automatic technologies; from third-party sites or apps, content distribution channels and platforms; from third-party business partners; and from social media platforms and similar services.	To perform our contractual obligations to you; to pursue our legitimate interests; to comply with our legal obligations; with your consent.	With service providers and/or business partners; with advertising and marketing service providers and partners; with content measurement companies; with professional advisors or legal counsel; with government authorities as required by law or as necessary to protect our rights.
Information you provide when you choose to participate in surveys, polls, sweepstakes, contests, or promotions.	Directly from you.	To perform our contractual obligations to you; to pursue our legitimate interests; to comply with our legal obligations; with your consent.	With service providers and/or business partners and partners; with advertising and marketing service providers and partners; with content measurement companies; with social media platforms; with professional advisors or legal counsel; with government authorities as required by law or as necessary to protect our rights.
Transactional and commercial activity information, such as requests, searches, or purchases.	Directly from you; from cookies and similar automatic technologies; from third-party sites or apps, content distribution channels and platforms; and from social media platforms and similar services.	To perform our contractual obligations to you; to pursue our legitimate interests; to comply with our legal obligations; with your consent.	With service providers and/or business partners; with advertising and marketing service providers and partners; with professional advisors or legal counsel; with government authorities as required by law or as necessary to protect our rights.
Internet protocol (IP) address, tenant URL, and geolocation information.	Directly from you; and from cookies and similar automatic technologies.	To perform our contractual obligations to you; to pursue our legitimate interests; to comply with our legal obligations; with your consent.	With service providers and/or business partners; with advertising and marketing service providers and partners; with content measurement companies; with professional advisors or legal counsel; with government authorities as required by law or as necessary to protect our rights.
Device identifiers and other information about your computer, device, browser and operating system.	From cookies and similar automatic technologies.	To pursue our legitimate interests (such as to ensure that an account is not being used by more than one individual without authorization, or to create new products).	With service providers and/or business partners; with professional advisors or legal counsel; with government authorities as required by law or as necessary to protect our rights.
Information about your interactions with email messages and other communications.	From cookies and similar automatic technologies.	To perform our contractual obligations to you; to pursue our legitimate interests; to comply with our legal obligations.	With service providers and/or business partners; with advertising and marketing service providers and partners; with content measurement companies; with professional advisors or legal counsel; with government authorities as required by law or as necessary to protect our rights.
Payment information for subscriptions or purchases, such as payment card number, expiration date, and billing information.	From third-party sites or apps, content distribution channels and platforms.	To perform our contractual obligations to you; to pursue our legitimate interests; to comply with our legal obligations; with your consent.	With service providers and/or business partners; with government authorities as required by law or as necessary to protect our rights.

The above table does not apply to special category personal information, which we will only process with your explicit consent.

6. Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the personal information you provide to us. 

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of these Websites may be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences on other sites. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

7. How We Respond to Do Not Track Signals. “Do Not Track” is a preference you can set your browser to let websites you visit know that you do not want them collecting certain information about you. We do not currently respond to, or honor, Do Not Track signals or requests from your browser.
8. Promotional Communications. We may use your personal information to send you updates about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at support@marinayt.com; or
• Using the “unsubscribe” link in emails or “STOP” command in texts. 

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

9. Who We Share Your Personal Information With. We routinely share personal information with:

• Service providers we use to help deliver our products and/or services to you, such as website providers, payment service providers, and/or data storage, hosting, and server providers;
• Other third parties we use to help us run our business, such as marketing agencies, information technology (“IT”) service providers, or independent contractors or consultants;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• Our insurers, brokers, or other professional advisors;
• Sponsors or promoters of any competition or promotion we run;
• Our bank; or
• Legal counsel, debt collectors, or any other entity for the purpose of establishing, exercising, or defending our legal rights; 

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors to ensure compliance with applicable data protection laws.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may disclose anonymized, statistical data and/or non-identifying information about our users without restriction.

We will not share your personal information with any other type of third party, unless we have your consent to do so.

10. Where Your personal information is Held. Information may be held at our premises in California, United States and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your personal information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your personal information Out of the EEA”.

11. How Long Your personal information Will Be Kept. We only collect information that we absolutely need to carry out the functions described in this Privacy Notice. We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary to:

• Maintain business records for analysis, understanding market trends and/or audit purposes and to improve the Websites.
• Respond to any questions, complaints or claims made by you or on your behalf;
• Defend, establish, exercise, or bring any existing or potential legal claims.
• Carry out fraud detection and prevention.
• Show that we treated you fairly; or
• Keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

12. Your California Privacy Rights. If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties for their own direct marketing uses. California’s “Shine the Light” Act provides that you have the right to submit a request to us at our email address in order to receive information on the categories of customer information that we shared and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To obtain this information, please send an email message to support@marinayt.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you in your email address in response.

Please be aware that not all information sharing is covered by the Shine the Light requirements, and only information on covered sharing will be included in our response.

13. Accessing and Correcting Your Information. If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can review and change your personal information by logging into your account profile on the Websites and navigating to the appropriate settings page or sending us an email at  support@marinayt.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete some of your personal information except by also deleting your User account. We may not accommodate a request to change information if we believe the change would violate any law or regulatory requirement, result in fraud, or cause the information to be incorrect.
14. Transferring Your personal information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA). These transfers are subject to special rules under European and UK data protection law.

Certain non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. 

If you would like further information, please contact us (see “How To Contact Us” below).

15. Your Rights Under the GDPR.

Right to Access	The right to be provided with a copy of your personal information (the right of access).
Right to Rectification	The right to require us to correct any mistakes in your personal information.
Right to be Forgotten	The right to require us to delete your personal information—in certain situations.
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
Right to Object	The right to object:at any time to your personal information being processed for direct marketing (including profiling);in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the EU’s European Commission’s Data Protection page or the UK Information Commissioner’s Office on individual rights under the General Data Protection Regulation.

16. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. 

Any payment transactions will be encrypted using SSL technology. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites. 

17. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Notice, please send an email to support@marinayt.com. You will need to provide us with:

• Enough information to identify you (e.g., your full name, address and any other relevant information);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

18. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority in your location is the entity who may be contacted.

19. Changes to This Privacy Notice. We may change this Privacy Notice from time to time. When we do, we will inform you via email or a notice on the homepage of the Websites.
20. How to Contact Us. Please contact us by email at support@marinayt.com if you have any questions about this Privacy Notice or the information we hold about you.

Our contact details are shown below:Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).