PRIVACY POLICY
Effective Date: October 25, 2024
Please read this Privacy Notice (herein referred to simply as “Privacy Notice” or “Notice”) before using this site or submitting any personal information. This Privacy Notice sets forth the extent of your TCPA Consent as well as our current practices with regard to information we collect from or about you and how we may use that information.
By using this web site, you accept and agree to be bound by the privacy practices contained in this Privacy Notice. This Privacy Notice may be updated from time to time, and any material changes will be posted within a reasonable time. You are encouraged to review the Privacy Notice whenever you visit the Sites to make sure you understand how your personal information will be used.
IF YOU DO NOT AGREE TO BE BOUND BY SUCH AGREEMENTS, THEN YOU MUST IMMEDIATELY CEASE ACCESS, BROWSING OR OTHERWISE USE OF THE SITES OR THE SERVICES.
Please read the Privacy Notice carefully, and note that by accessing the Sites or using the Services, you are bound to the MANDATORY ARBITRATION PROVISION and WAIVER OF CLASS ACTION PROVISION outlined in the Terms & Conditions.
1. Introduction
Welcome! You have arrived at a website operated by The Wellspring Group, LLC or our affiliates (“TWG,” “we”, “our” or “us”). In this Privacy Notice, “you” and “your” means the person agreeing to this Privacy Notice and also any individual you authorize to communicate or act on your behalf (or that is authorized by law to communicate or act on your behalf), or with who we may communicate about or concerning you.
At TWG we take your privacy very seriously. This Privacy Notice describes the types of personal information (as defined below) that we collect, how we use it, how and when we share it, and the rights you have with respect to your information. It also explains how we communicate with you and how you can make inquiries and requests to us about your information. We strive to help you understand how we use your information to improve our products, services, marketing, and interactions with you, as part of our commitment to maintaining your trust.
If you reside in the European Union, please also see those Sections below for additional rights that may apply to you.
2. Scope
This Notice applies when you use or access any of the websites, landing pages, webforms, or digital properties owned, operated, or maintained by TWG, including but not limited to thewellspring.group and its respective subdomains, portals, or digital extensions (collectively referred to as the "Sites"). This also includes any other digital properties or resources that link to this Privacy Notice, whether accessed via desktop, mobile, or other devices. This Notice also applies when you provide Personal Information or interact with us online or in-person at a live event.
For the purpose of this Notice, "Personal Information" refers to any data that can be used to identify a specific individual, either on its own or when combined with other information. This can include both direct identifiers and indirect identifiers
“Services” refers to all activities, features, and functionalities offered through our websites, platforms, and online portals, including but not limited to access to content, products, and information provided via our websites (such as thewellspring.group), as well as live events, webinars, communication tools, and any related support or interactions you may have with The Wellspring Group, LLC, whether online or in person. This also includes any landing pages, webforms, subdomains, or associated digital or physical services provided by TWG.
By using the Services, you agree to our Terms & Conditions. By accessing and/or using any of the Services in any way, or by communicating and/or interacting with us in any way (whether initiated by us or by you), you acknowledge, fully understand, and consent to our Privacy Notice (including TCPA consent), and freely agree to the information collection and use practices described in this Privacy Notice.
You understand and agree that this does not impact any of the other methods you have additionally authorized or that are utilized by us to transact business or to communicate with you.
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it.
If you have any questions about this Privacy Notice, please contact us at [email protected].
3. What Information We Collect
Information That You Provide to Us
We may obtain Personal Information from you where you expressly provide us with the information. For example, we may collect information from you via:- Telephone calls with you;
- Letters, e-mails or other communications from you, including text messages;
- Information provided in online chat or support services, web forms or inputs/uploads into our Site, documents you have provided to us; or
- References and referrals provided to us in connection with your employment applications.
- Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers;
- Financial information such as your credit card or debit card number, bank account information and your payment, service and purchase history;
- Information that you share via the chat function on the Sites (please note that we do not collect consumer information via the Sites’ online chat or Contact Us function unless you provide it);
- If you apply for employment with us, we collect your current or past employment or educational information;
- Social media information, such as social media handles, content and other data shared with us through third-party features that you use on our Sites and other service (such as tools, payment services, widgets and plug-ins offered by social media services like
- Facebook, Instagram, Twitter and Vimeo) or posted on social media pages (such as our social media page or other pages accessible to us);
- For our employees, we collect social security number, passport, and drivers license information; and/or Other information that could reasonably be used to identify you personally or identify your household or device.
Information That Is Automatically Collected
Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Sites and Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:- Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
- Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
- Referring and exit web pages and URLs;
- The areas within the Sites that you visit and your activities there, including remembering you and your preferences;
- Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
- Your Device characteristics;
- Certain other Device data, including the time of day you visit our Sites or other information used to provide analytics or other usage information;
- Information about your engagement with our emails; and
- Based on information you give us, we aggregate information about how both unregistered and registered users, collectively, use the Sites and Services and use it for statistical purposes. This aggregate information cannot be tied back to you or your web browser.
Information Collected from Third Parties
We may license or collect information about you, including Personal Information, from other companies and organizations, such as event or promotion co-sponsors, including to supplement information that we receive from you. In some cases, we may receive information about you from affiliated entities, which we handle in accordance with this Notice. By collecting additional information about you, we can correct inaccurate information, enhance the security of your interactions with us and help prevent fraud, and give you recommendations and special offers that are more likely to interest you. The Sites may also include functionality that allows certain kinds of interactions between the Sites and your account on a third-party websites or application. The use of this functionality may involve the third-party websites providing information to us. For example, we might use third party functionality to:- obtain information about the traffic and usage of our Sites;
- facilitate sending a communication from the Sites; or
- facilitate sending emails or sharing postings to social media (via a “Share” or “Forward” button).
4. How We Use Your Personal Information
We may use the information we collect about you as follows:
To Provide Our Services
We process certain personal information when you access or use our Services, including to:- process your purchases of, or requests for, our Services such as hosting a webinar or workshop, delivering an online course or a live workshop or emailing about your use of our Services;
- register and verify user accounts;
- facilitate the functionality of our Site, including processing payments; and
- customize experiences and personalization when you are using our Sites and Services.
To Communicate with You
We process certain information in order to communicate with you in relation to your accounts, our Services, our marketing, and your requests, including but not limited to:- communicate with you about orders, purchases, services, accounts, programs, contests, and sweepstakes;
- respond to your customer service inquiries and requests for information;
- post your comments or statements on our Site;
- send you personalized promotions, content, and special offers;
- communicate with you about our Services, events, or other promotional purposes;
- communicate with you about our partner’s products, services and events;
- send SMS messages (including text messages) about our Services, events, or other promotional or marketing purposes to you after you have opted-in to receive such messages. (Text message rates may apply; you may unsubscribe from these communications at any time);
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- Notwithstanding any current or prior election to opt in or out of receiving telemarketing calls or SMS messages (including text messages from your mobile phone) from us, our agents, representatives, affiliates, or anyone messaging on our behalf, you expressly consent to be contacted by us, our agents, representatives, affiliates, or anyone messaging on our behalf for any and all purposes.
- You authorize us to manually dial or use automated dialing technology to dial any telephone number(s) (including but not limited to wireless/cellular phone numbers) which you or anyone acting on your behalf provide to us at any time, for any and all purposes. You further acknowledge and agree that we may leave pre-recorded and/or artificial voice messages and/or send individual or mass-generated text messages (such as SMS and/or MMS and/or two-way texting) to such number(s) using manual or automatic texting systems for any and all purposes, and that message and data rates may apply. The information we collect will primarily be used by us to (i) provide notices regarding your account or account activity, (ii) investigate or prevent fraud, or (iii) collect a debt owed to us.
- In addition, you agree that by submitting your land line telephone or mobile telephone contact information on any of the Sites and/or registering to receive the product and/or Services offered herein, such act constitutes a purchase, an inquiry, and/or an application for the purposes of the Amended Telemarketing Sales Rule (ATSR), 16 CFR ‘310 et seq. and any applicable state and local “do not call” regulations. We retain the right to contact you via telemarketing in accordance with the ATSR and the applicable state regulations.
- In providing your express consent, you understand that we may also use the information we collect to offer up the services of one or more third-party service providers. However, we do not share your mobile phone with any third parties, and we do not sell any of the information we collect.
- YOU EXPRESSLY AGREE THAT WE MAY CONTACT YOU EVEN IF YOU HAVE PREVIOUSLY REGISTERED YOUR PHONE WITH A FEDERAL OR STATE “DO NOT CALL” REGISTRY.
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- You do not have to consent to receive phone calls and text messages. You have the right to withdraw your consent and may opt-out of receiving phone calls by contacting us in any of the methods listed in the “Contact” section of any of our Sites. In addition, you may opt-out of e-mails by clicking the “unsubscribe” link in any e-mail we send to you, and may opt-out of text messages by replying “STOP” to text messages you receive from us or by contacting us using the contact information below. Any STOP or unsubscribe selection applies only to future text and email messages. Any withdrawal of your consent will not apply to any electronic communication(s) previously sent or in process. Your withdrawal will become effective only after we have had a reasonable time to process your withdrawal request. Therefore, you may still receive communications for a period of time after you withdraw your consent. If you withdraw your consent and then re-enable any of these Services, you will be deemed to have again given us your express written consent to contact you via any services you re-enable.
- implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; and
For Research, Development, and Improvement of Our Services
We want to ensure that our Sites and Services are continually improving to meet and exceed your needs and expectations. As such, we may process certain Personal Information, including to:- maintain, improve, and analyze our Sites and Services; and
- detect, prevent, or investigate suspicious activity or fraud.
To Enforce our Terms, Agreements, or Policies
To create and maintain a safe, secure, and trusted environment for you when you use our Sites and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.To Comply with Applicable Laws
We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:- maintain appropriate records for internal administrative purposes; and
- comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.
Evaluate Your Application for Employment
We may process certain Personal Information to evaluate your application for employment with us and/or administer employment benefits.With Your Consent
We may process certain personal information in order to fulfill any other business or commercial purposes at your direction or with your consent.5. Use of Cookies
We use cookies and other tracking technologies to personalize your experience, analyze user trends, and improve the Services. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Site, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information.
You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Site. For example, we may not be able to recognize your computer or device, and you may need to log in every time you visit.
We may use “cookies” (a small text file sent by your computer each time you visit our site) or similar technologies to record log data. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options.
We may use the following types of cookies:
- Advertising cookies
- Essential cookies
- Functionality cookies
- Social Media cookies
We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the Sites and provide us with information based on your interaction with the site. These tags may collect the IP address from the device which you loaded the page, the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements.
Other data technologies may be used that collect comparable information for security and fraud detection purposes.
If you have any questions about cookies or to generally find out more about cookies, visit this site.
6. Your Choices
Do Not Track
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites and platforms. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed-upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.
Communication Preferences
To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails from us at any time. To manage your communications preferences with TWG — or to opt out of communications entirely — please select “unsubscribe” at the bottom of our emails or contact us at [email protected].
Analytics
We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
7. How We Share Your Information
Services Providers
We share your Personal Information with our third-party service providers who provide services such as websites hosting, payment processing, online chat functionality, data analysis, information technology, customer service, email delivery, online advertising, auditing, event planning and other services.
TWG Affiliates
We will share your personal information, except mobile phone information, with third parties as provided in this Privacy Notice. By consenting to this Privacy Notice, you also authorize us to share your information with our affiliates, partners, and third-party service providers as outlined herein. By permitting us to collect this information, you will be able to receive information on other products and services that may be of interest to you, including related third party offers that we may send to you. You also enable us to personalize your experience with us so that we can provide you with the highest quality of service. We may also use this information to contact you about joint venture opportunities if it appears that you would be a suitable joint venture partner. If we should ever file for bankruptcy, or become insolvent, or be acquired by a third party, or merge with a third party, or sell all or part of its assets, or transfer substantially all or part of its relevant assets to a third party, then we are entitled to share the personal information and all other information you have provided through the products and services to potential and subsequent business and merger partners.
Third Party Advertising
We share information about your use of our Sites and Services, including your video viewing habits, your purchases, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
Many advertising companies that collect information for interest-based advertising are members of the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA), both of which maintain websites where individuals can opt out of interest-based advertising from their members. For more information about how targeted advertising works, you can visit NAI’s educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal at http://optout.aboutads.info/, the DAA of Canada’s opt-out portal at https://youradchoices.ca/en/tools, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.
You can opt out of targeted advertising by visiting the following:
- Facebook - https://www.facebook.com/settings/?tab=ads
- Google - https://www.google.com/settings/ads/anonymous
- Bing - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
- LinkedIn - https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Other
Aside from the instances described above, we will only share your personal information:- to comply with the law;
- to respond to claims or comply with legal process served on TWG (e.g., a lawful subpoena, warrant, or court order);
- to enforce or apply our policies or agreements;
- to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
- in connection with a business transfer, sale, liquidation, or merger;
- if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
- with your consent.
8. Third Party Links
Our Sites may contain links to other websites such as social media platforms, other websites, and event and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties.
9. International Transfers of Data
These Sites are operated in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using these Sites and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). Our service providers use appropriate safeguards to transfer your Personal Information to the United States.
8. Withdrawing Consent
To stop receiving future communications or solicitations from us, please unsubscribe according to the instructions contained in any correspondence you receive from us.
To unsubscribe from a third-party service, you must contact that third party directly.
10. Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us at [email protected].
11. Your Rights Under the General Data Protection Regulation
This section of our Privacy Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopted this Notice to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this Section. In most instances, TWG is the data controller for processing Personal Information provided to us through the Site.
We hope to ensure that the Personal Information we possess are always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice.
If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Information.
- The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where TWG relied on your consent to process your Personal Information.
Exercising Your Rights Under GDPR
If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us using the contact details below. You may make a request related to your Personal Information or on behalf of someone for whom you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.
Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.
Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:
The Wellspring Group, LLC
PO Box 63138
Colorado Springs, CO 80962
United States of AmericaEmail: [email protected]
Legal Basis for Processing Personal Information
We rely on the following legal bases for processing your Personal Information:
- Processing of your Personal Information that you provide to us when you interact with our Sites and Services, watching our videos or making a purchase, is necessary to respond to or implement your request prior to entering into a contract with us.
- When you apply for employment through our Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.
- We use account-related data to set up accounts for users in our platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and us.
- We will send you information by email on our new services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.
- Our use of data relating to your use of the Sites and/or the Services, described above, is necessary for our legitimate interests in understanding how the Sites and the Services are being used by you, to improve your experience on it and our Services offerings. We have also a legitimate interest in aggregating and/or anonymizing the information that we collect through our Sites and/or the Services and using this information for our business purposes, as described above. When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.
Retention of Personal Information
TWG will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.All information you provide to us is stored on our secure servers or those of our third-party data storage providers.
12. Children's Privacy
Our Sites and Services are not directed at children under 18 years of age, and we do not knowingly collect or receive Personal Information from them. If we learn that we have received Personal Information from a child who is under 18, we will delete the data. If you believe that we have received Personal Information from a child under the age of 18, you may contact us at [email protected] to request deletion of that information.
13. Changes to This Privacy Notice
We maintain the discretion to change or update this Privacy Notice at any time. When we do, we will post all changes to this Privacy Notice on this page and will indicate at the top of the page the modified notice's effective date. We therefore encourage you to review this Privacy Notice on an ongoing basis and to stay informed about how we are using and helping to protect the personal information we collect. If required by the applicable law, we will notify you of the changes. Your continued access to and/or use of any of the Sites and/or the Services constitutes your agreement to this Privacy Notice and any update(s) or change(s) to it.
14. Severance Clause
If any provision of this Privacy Notice is held to be invalid, illegal, or unenforceable (whether in whole or in part), such provision will be deemed modified to the extent, but only to the extent, of such invalidity, illegality or unenforceability and the remaining provisions will not be affected thereby; provided that if any of such provision is finally held to be invalid, illegal or unenforceable because it exceeds the maximum scope determined to be acceptable to permit such provision to be enforceable, such provision will be deemed to be modified to the minimum extend necessary to modify such scope in order to make such provision enforceable hereunder.
14. Contact Us
If you have any questions or suggestions regarding this Privacy Notice, please contact us at:
The Wellspring Group, LLC
PO Box 63138
Colorado Springs, CO 80962
Email: [email protected]
Contact number: (719) 285-0738
You acknowledge access and agreement to this Privacy Notice by: (1) signing it; or (2) accessing and or utilizing any Sites and/or link(s) owned and maintained by us, or (3) by communicating and/or interacting with us in any way via any text/SMS/MMS/two-way texting message platform (whether initiated by us or you), or (4) by submitting your information and checking the consent box on any of our Sites.
