Privacy Policy

1. Purpose

This policy applies to all processing of personal data carried out by Impactful Today and aims to inform you about how Impactful Today carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and about your rights in relation to your personal data.

2. Contact - How can I contact you?

In case you have any questions about the Privacy Policy, you can contact Impactful Today by the following means:

• The registered office is located at: 7 Ashton Heights

You may establish direct and effective communication with Impactful Today by written communication sent to any of the addresses indicated or also by sending an email message to: [email protected]
In addition, the information of the employee in charge of processing your personal data is listed below:

• Business name: Impactful Today
• Identity of controller: Impactful Today LTD
• Address: 7 Ashton Heights
• Email: [email protected]

3. Identification Processing - How do we collect personal data?

In accordance with the current regulations on the protection of personal data, especially,

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the 'GDPR'),

Impactful Today collects personal data in its possession when you:

• (i). completes the impactful.today ('Site'), company's app and/or platform forms;
• (ii). subscribes to the newsletter;
• (iii). responds to a survey or fills in a web form;
• (iv). fills out a paper form;
• (v). sends an e-mail or communicates by telephone, which are then loaded into the corresponding forms;

4. Personal Data Collected - What personal data do we collect?

Impactful Today collects information when by visiting its website, using your app and/or platforms, and primarily by completing its registration forms.

The following data is collected: e-mail, address and credit information.

As a general rule, when personal data is requested in order to use a service or access certain content, its delivery shall not be obligatory, except in those cases in which it is specifically indicated that it is necessary for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.

The user declares and guarantees that all of the data provided are true and correct and undertakes to keep them up to date. Any changes may be communicated to the Data Protection Officer or to the address indicated in Section 2 of this document.

Likewise, you acknowledge that the data required by Impactful Today is necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data were not provided.

Any misrepresentation or inaccuracy that occurs as a result of the information and data provided, as well as the damage that such information may cause, shall be the responsibility of the user.

5. Purpose - What do we use personal data for?

The personal data requested from the user will be used for the following purposes:

• In case of contracting services offered through the Site, to create and maintain the business relationship, and to carry out the activities and provide the services of Impactful Today (including, without limitation, the management, administration, provision and improvement of the services).
• Send newsletters, as well as commercial communications, promotions and/or announcements from Impactful Today, occasionally or periodically. Consequently, the email address you provide when completing the form on the Site may be used to send you information and updates on your request for services, as well as news about Impactful Today (occasionally or periodically), updates, information on related products or services, among others. This processing is based on our legitimate interest in promoting our products and services.
• To carry out a survey or a competition
• To personalise the user experience by enhancing our ability to respond to your needs
• To improve Impactful Today's Site and service offering, based on Impactful Today's legitimate interest in constantly improving its products and services.
• Process transactions and comply with legal obligations to which Impactful Today is subject, such as tax obligations. The data subject to processing shall not be used for purposes other than or incompatible with those mentioned above and which motivated their collection. Notwithstanding the above, it is hereby stated that the recorded data may be used, in addition to the purposes for which they were expressly collected, for the purposes of statistics, incident management or carrying out market research. However, should personal data be processed for a purpose other than that initially specified when the said data was collected, a compatibility analysis will be carried out by Impactful Today in compliance with the applicable regulations. Processing will only be allowed if the original purpose is compatible with the new purpose or permitted according to an independent legal basis. In such cases, you will be informed of the changes in purpose or legal justification for processing your data.

You are reminded that you may object to receiving commercial communications from Impactful Today (unsubscribe) and stop receiving emails from Impactful Today by giving Impactful Today reliable notice, which will stop as soon as possible after receipt of such notice. For this purpose, you may send an email to the address set out in Section 2 or directly follow the unsubscribe instructions detailed at the end of each email from Impactful Today.

6. How do we use your information?

We will use the information we collect about you for the following purposes:

• Administration info
• Creating user account
• Testimonials
• Customer feedback collection
• Enforce T&C
• Manage customer order
• Support
• Targeted advertising
• Administration info
• User to user comments
• Site protection
• Dispute resolution
• Manage user accounts
• Processing payment: Stripe

If we want to use your information for any other purpose, we will ask for your consent and use your information only when we receive your consent and then only for the purpose(s) for which consent will be granted, unless we are required by law to do otherwise.

We will retain your personal information with us for 24 months after user accounts remain idle or for as long as necessary to fulfil the purposes for which it was collected, as detailed in this Privacy Policy.

You can raise a data request using the following form.

7. Consent

By providing personal data to Impactful Today, the user declares to accept its processing fully and without reservation by Impactful Today. The user gives his/her free, express and informed consent to Impactful Today's use of the data collected for the purposes indicated in Section 5, as well as its incorporation into a Impactful Today database.

The Impactful Today carries out the processing of legitimised user data: (i) the contracting of Impactful Today services by the user, in accordance with the terms and conditions that are made available to the user at the end of the completion of the service request form (prior to possible contracting) and which the user (after reading them), and if the user agrees, can accept by ticking the box that has been included for this purpose; and (ii) the free, informed and unambiguous consent of the user, made after reviewing this privacy policy, where Impactful Today informs you of the processing it will carry out with your data, and if you agree, by ticking the box that has been included for this purpose in the service request form. Data processing that is not covered by any of the above legal bases will be carried out if Impactful Today considers it necessary to protect a legitimate interest and only if it does not infringe the fundamental rights and freedoms of the user.

8. Validity - How long do we keep it?

The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes described in Section 5 above. In particular, personal data will be kept for as long as the business relationship is in force (and to the extent that you have not previously requested their deletion) and for as long as obligations, indemnities and/or liabilities may arise under the business relationship or for the services provided.
Impactful Today informs you that it will retain information essential to identify the origin of the data stored for the duration of the client's relationship with Impactful Today and/or revocation of the user's consent in accordance with the information in Section 5 of this Privacy Policy and/or as long as required by applicable law.

9. Confidentiality / Assignment / International Transfer - Do we disclose data to third parties?

Impactful Today will keep collected personal data private and confidential, and will not use it for purposes other than those set out in Section 5 hereof. Impactful Today requires its employees and third parties providing services that access the contents of the databases to sign confidentiality and personal data processing agreements (or include such obligations in the service agreements it signs with such providers, as indicated in the following paragraph).

The user's personal data collected by Impactful Today will not be transferred, sold, exchanged, transmitted and/or communicated to third parties outside Impactful Today without the user's consent, except for legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers enabling Impactful Today to keep the Site operational, fulfil the objectives set out in Section 5 of this document and/or provide services to the user, who have undertaken the obligation to maintain the confidentiality of the data provided and undertake to comply with applicable regulations on the protection of personal data, at the time of contracting. Contracts with service providers stipulate the purpose, scope, content, duration, nature and purpose of data processing, the type of personal data, the categories of data subjects and the obligations and responsibilities of Impactful Today and contracted third parties.

In particular: Impactful Today may share the personal information provided with parent companies, affiliates, subsidiaries, related companies and/or intermediaries related to Impactful Today.

Impactful Today may share certain user-provided personal information internally within Impactful Today, with certain departments, such as administration, marketing, or IT.

**- In certain cases, Impactful Today transfers personal data based on legitimate interests and the economic and technical advantages associated with the use of specialised providers. In this regard: - YouTube. The Site links to YouTube in relation to videos linked to Impactful Today services. As indicated in Section 13, by using these links the user leaves the Site and is redirected to the YouTube page. You can view YouTube's privacy policy and other legal aspects at the following link: https://policies.google.com/privacy - Facebook. Impactful Today has integrated Facebook components into the Site. In particular, Impactful Today uses the Facebook advertising platform. The company operating the Facebook services is Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The user can consult the privacy policy and other legal aspects of that company at the following link: https://www.facebook.com/privacy/policy. - Twitter. The Site has links to Twitter. As indicated in Section 13, by using these links the user leaves the Site and is redirected to Twitter. The user can view Twitter's privacy policy and other legal aspects at the following link: https://twitter.com/en/privacy. ** **- Social Networks. Impactful Today also uses social networks, such as Facebook or Instagram, and has integrated functions of these networks into its services. The user can only use these social networks insofar as they are registered on them and have accessed the corresponding social network with their user. These social networks have their own privacy policies and their own terms and conditions, over which Impactful Today has no interference or control. **

Finally, you should be aware that Impactful Today may (and that Impactful Today reserves the right to) disclose your information in the following cases: (i) if required by a judicial or administrative authority; (ii) if necessary to exercise your rights under the Terms and Conditions of Impactful Today and this Privacy Policy; (iii) if necessary to comply with the law; (iv) if such data may be useful for the protection of the rights of third parties; (v) if it is useful for the protection of the rights, property or safety of Impactful Today, its controllers, subsidiaries, affiliates, directors, managers, employees, users or the general public; and (vi) if there are well-founded reasons relating to public safety, national defence or public health.

10. Security - How do we ensure data security?

Impactful Today declares its intention to adopt the necessary technical and organisational measures to ensure the security, integrity and confidentiality of the data in accordance with the provisions of GDPR in order to prevent its tampering, loss, consultation or unauthorised processing. In particular, all credit data provided is transmitted via SSL (Secure Socket Layer) and encrypted in the database of the payment platform of the provider of these payment services. It is stated that the credit data (credit card number, among others) is not stored on Impactful Today servers nor on Google Drive. In order to ensure the confidentiality of the processing, the payment service provider is contractually obliged to respect the confidentiality of the information.

Impactful Today does not guarantee absolute privacy when using the Site, since the possibility that unauthorised third parties may have knowledge of it cannot be excluded. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are taken, it is possible to suffer manipulation, destruction and/or loss of information. In the event that a security incident is detected and entails a significant risk to the data owner, such event will be reported without delay to the competent control authority, together with the corrective and remedial measures implemented and/or to be implemented.

Impactful Today is not responsible for the loss or deletion of data by users. Similarly, Impactful Today accepts no responsibility for possible damage caused by computer viruses.

Finally, the user must also take measures to protect their information. Impactful Today insists that you take every precaution to protect your personal information while on the Internet. At the very least, it is advisable to change your password periodically, using a combination of letters and numbers, and to make sure you are using a secure browser.

11. Data owner rights and procedures to respond to their exercise - What rights do I have as a data owner?

The data owner user may at any time exercise the rights of access, rectification, cancellation, opposition, limitation of processing, portability, confidentiality and deletion of his/her personal data, in accordance with the provisions of Articles 15 et seq. of the GDPR, as applicable.
The exercise of these rights may be carried out by the user him/herself by means of an e-mail addressed to [email protected], or by written communication addressed to the Data Protection Officer at the following address [email protected], or by any of the methods provided for in the applicable regulations referred to above. Impactful Today may request the data necessary to validate the identification of the data owner.

The deletion of some data shall not be carried out where it may cause damage to the legitimate rights or interests of third parties, or where there is a legal obligation to retain the data.

12. Appointment of a Data Protection Officer Company Name has appointed a delegate for the enforcement and control of this Privacy Policy and the relationship with the enforcement authority to Edmund Ellison who can be contacted by the following means:

• Email: [email protected]
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13. Training - Do we train?

The staff of Impactful Today whose functions are related to the processing of personal data are trained in order to ensure better protection of personal data and the rights of data subjects.

14. Links to third parties - Does our Site contain links to other websites?

The Site may contain links to third party websites, with or without advertising content, whose privacy policies are foreign to Impactful Today. The linked sites are not related to Impactful Today and, their existence in no way presupposes that there is any kind of suggestion, invitation or recommendation to visit the target sites or any kind of link or association between Impactful Today and such sites. Impactful Today is not responsible for the content, use and activities of these linked sites, or for any actual or potential, material or moral, direct or indirect damages suffered by users and derived from the information contained in such sites or the relationship that users may establish with third parties whose services have been published on the Site. Notwithstanding the above, any feedback on these linked sites will be useful to Impactful Today in order to improve the services and/or ensure the integrity of the Site. Impactful Today undertakes to do everything possible to prevent the existence on its Site of links to sites with illegal content.

15. Cookies - Do we use cookies?

When you visit the Site, Impactful Today may store certain information on your computer in the form of a "cookie" or similar file. The Site uses cookies to (i) track advertising, (ii) collect traffic data from the Site, and (iii) improve the user experience when using the Site.

The user should be aware that, in order to browse the Site, it is not necessary for him or her to allow the installation of cookies sent by the Site. This may only be required in relation to certain services. You may delete cookies from your computer hard drive, prevent access to your computer through your browser or by choosing the corresponding option when asked about the possibility of using cookies for these purposes and in accordance with Impactful Today Cookie Policy.

Cookies are files of information that a website or the provider of certain services on the site transfers to the hard drive of the user's computer via the browser. Cookies by themselves cannot personally identify the user (although they may contain the user's IP address) but they allow them to recognise the user's browser, and to capture and store certain data (the user's operating system, the domain name of the website from which the Site was linked, among others). Impactful Today reserves the right to hire the services of third parties to analyse and understand the users of the Site, who may not use the information collected for purposes other than improving Impactful Today's services.}

16. Approval

Your use of the Site constitutes your acknowledgement and approval of Impactful Today's Privacy Policy and Impactful Today's Terms and Conditions, if any. Likewise, the user accepts Impactful Today's Privacy Policy and Impactful Today's Terms and Conditions by completing the request for services.

17. Modifications - Is this the most current version?

This is the current version of the Impactful Today Privacy Policy, updated on June 30, 2023.

Impactful Today may, at any time and without notice, modify this Privacy Policy. Such modifications will be operative as of their publication on the Site or when they are notified to users by any means, whichever occurs first. The user must keep informed of the terms included herein by logging in periodically.