Elizabeth Cifers Consulting Website Privacy Policy

Your use of the Website indicates your acceptance and agreement with this Privacy Policy and any updates. By using the Website, you give your consent that your personal data may be processed by us and third parties as described herein. If you do not agree to the terms of this Privacy Policy, do not use our Website. This Privacy Policy does not apply to websites, services, or applications where it is not posted or that are run by third parties, and you should reference the respective third-party privacy policies for information on how they may collect and use your data.

1. What types of personal data do we collect?

We may collect the following types of “personal data,” which includes information which is related to an identified or identifiable natural person:

• Personal identifiers, such as your first and/or last name, email address, mailing address, phone number, etc.
• Computer, device, and technical information, such as your device and usage information including Internet Protocol addresses and location, or other unique personal identifiers such as cookies and web beacons.
• Course account information, if you buy our online course or are given access to it: your name, email address, practice and role, your seat, and your course progress (which videos you watched and how far). We also keep records of your payments (amount, date and payment references). Card details are handled by our payment processor and are never stored by us.
• Security records of each sign-in and each course video session: the time, your IP address and your browser.

We do not collect health information from visitors of our Website and ask that you not share any such information on or via our Website.

2. How do we collect your personal data?

You directly provide us with most of the data we collect, such as personal identifiers when you chose to provide such information when opting-in to receive information or documents from our Website, or when you utilize our online scheduling assistant feature. We also collect data when you buy our online course, when your practice manager adds you to a team, and when you use the learning portal.

We may also collect data when you use or view our Website via your browser’s cookies, web beacons, or similar technologies, including through our third-party partners for analytics and marketing purposes, as described in section 8.

3. How do we use your personal data?

We collect and use personal data for legitimate business purposes, such as in order to:

• Provide services to you that you request, such as sending out newsletters or informational materials to you that you have requested.
• Communicate with you, such as responding to your requests or questions, presenting our Website, or sharing important information or updates with you.
• Provide our online course and your account: set up your account, send sign-in links and one-time sign-in codes, take payments, send receipts, send reminders 30, 7 and 1 days before your renewal date while auto-renew is on (and, for practices without auto-renew, before your end date, to add or confirm a payment method), send notices about payments, show your course progress to you and, for practice accounts, to your practice manager, and keep accounts secure. To discourage sharing, course videos show the viewer’s email address as a watermark.
• Support our business functions, such as improving our products and services (including the Website), detecting and repairing system performance issues, and to better understand how visitors use our Website. We may hire third parties to help us collect and analyze such data, and we may share such statistical data with third parties. We may use this information to help us make our Website more useful to visitors such as to learn about the number of visitors to our Website, what part of the Website they are interested in, how long the use the Website, the types of technology our visitors use, etc.

We keep your course account information, including your course progress and payment records, after your access ends, so you can pick up where you left off if you renew. You can ask us to delete it, as described in section 6.

4. How do we maintain and protect personal data?

We have implemented and maintain reasonable industry standard security measures to protect the security of your personal data. However, despite our safeguards and efforts to secure your data, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, and we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, or modify your data. Thus, you should only access the Website within a secure environment, and any provision or transmission of personal data to and from our Website is at your own risk.

5. When and with whom do we share personal data?

We do not sell personal data for money. We share personal data only in these cases:

• With companies that work for us. They host and protect our sites (including against bots and spam), monitor errors, send our emails, take payments, run our newsletter and booking tools, and provide the accessibility tool on our website.
• With your practice. If your practice gave you a seat, your practice manager sees your name, email address and course progress.
• When the law requires it, or to protect our rights, as described in our Terms of Use.
• With Google Analytics, beehiiv and Microsoft Clarity. They collect information from your browser through cookies and similar technologies, for analytics and session replay, as described in section 8.
• With Google, for its advertising features, as described in section 8. They are on by default in the United States and most other places; where we ask first, they stay off until you allow them. You can turn this off at any time with the “Your Privacy Choices” link at the bottom of every page, or by turning on Global Privacy Control in your browser.

6. What are your consumer rights?

• Right to access – Consumers may request that we provide them access to and copies of their personal data. We may charge you a small fee for this service.
• Right to correct – Consumers may request that we correct, complete, or update any information they believe is inaccurate.
• Right to delete – Consumers may request that we delete their personal data, under certain conditions.
• Right to restrict certain uses – Consumers may opt-out of our processing of their personal data and/or request that we restrict the processing of their personal data for certain purposes, under certain conditions.
• Right to data portability – Consumers may request that we transfer the data that we have collected from them to another organization or to them, under certain conditions.

If you would like to exercise any of these rights, please contact us at our email info@elizabethcconsulting.com or call us at 804-512-1883.

7. Rights of visitors in certain states.

Visitors residing in certain states may have different or additional rights regarding their personal data than the rights described above.

California Residents

The California Consumer Privacy Rights Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) provide additional rights to California residents. This section addresses those rights and applies only to California residents.

In the past 12 months, we have collected the categories of personal data (defined as “personal information” under the CCPA/CPRA) described above in our “What types of personal data do we collect?” from users of our Website. We have not collected “Sensitive Personal Information” as defined under the CPRA in the past 12 months. For example, we only collect non-precise geolocation data, including location derived from an IP address, and not precise geo-location information or other sensitive personal information.

We collect and use personal data for the business and commercial purposes described above in the “How do we use your personal data?” section. We do not sell personal data for money. Some of what we do may count as a “sale” or “sharing” under California law:

• Google Analytics, beehiiv and Microsoft Clarity collect information from your browser through cookies and similar technologies, for analytics and session replay.
• Google may use data about your visits for its advertising features, which can include ad personalization (see section 8). This may count as “sharing” for cross-context behavioral advertising.

You can opt out of any sale or sharing at any time with the “Your Privacy Choices” link at the bottom of every page, where you can also turn analytics off; in California, that link shows the California opt-out icon before it. If your browser sends a Global Privacy Control signal, we turn Google’s advertising features off automatically. You can also email us at info@elizabethcconsulting.com.

Our Website is not marketed to or intended for visitors under age 18, and we do not knowingly sell or share the personal data of minors under 16 years old who are California residents.

California residents can also designate an authorized agent to submit requests on their behalf. We will take reasonable steps to verify your identity and the identity and authority of your authorized agent prior to complying with any request.

If you are a California resident and would like to exercise your legal rights under the CCPA and CPRA, including the right to “opt-out” of the sale or sharing of your personal information as described herein, please contact us at info@elizabethcconsulting.com. You have the right to not be discriminated against for exercising your consumer rights. Please note that certain information may be exempt from such requests under California law.

Annually, California residents may request (i) a list of categories of personal information disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please contact us at info@elizabethcconsulting.com and specify you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Other States

For visitors of the Website residing in Colorado, Connecticut, Montana, Nevada, Virginia, Tennessee, Texas, or Utah, and in other such states not explicitly listed, state law may grant you additional rights with regard to your personal data under applicable law. You or your legally designated representative may submit a request to exercise your rights under applicable law by contacting us at info@elizabethcconsulting.com.

8. Cookies and your choices.

Cookies are small files a website saves in your browser. We use them on www.elizabethcconsulting.com, on our course page (course.elizabethcconsulting.com) and in our learning portal (app.elizabethcconsulting.com). This section is also published as our Cookie Policy.

Necessary cookies. They keep you signed in to the learning portal, keep sign-in secure and remember your cookie choice. Our website is also protected by Cloudflare, and our newsletter sign-up form (provided by beehiiv) uses security cookies from beehiiv and its bot-protection providers to block spam sign-ups. These cookies are always on.

Analytics. Google Analytics and beehiiv (the service behind our newsletter sign-up form) show us which pages and lessons people use and how they found us, so we can improve the site and the course. Google Analytics records your approximate location (down to your city, worked out from your IP address) and details about your device.

Session replay. On our website and course page only, Microsoft Clarity can record how pages are used (clicks, scrolling and mouse movement) as session recordings and heatmaps. It is off unless you turn on “Session replay” in your privacy choices, or click “Accept all” where we ask first. It never runs in the learning portal.

Google advertising features. Our Google Analytics has “Google signals” turned on, which gives us reports on age ranges and interests. When “Advertising” is on, Google can link your visits to our sites to your Google account. This only happens if you are signed in to Google and have ad personalization turned on there. For this, Google uses its own advertising cookies and identifiers along with our Google Analytics cookies. We see only grouped reports, never who you are. No Google Ads account is linked, so we do not use your visits to show you ads. In the United States and most other places, “Advertising” is on unless you turn it off or your browser sends a Global Privacy Control signal. Where we ask first, it stays off until you allow it, and until then we tell Google not to use your visits for advertising. You can opt out at any time in Google’s ad settings (adssettings.google.com) or with Google’s opt-out add-on for your browser (tools.google.com/dlpage/gaoptout).

Newsletter sign-up form. The newsletter sign-up form on our website is provided by beehiiv inside a frame on our page. Inside that frame, beehiiv runs its own tools, including Google Tag Manager and Cloudflare Web Analytics, under its own control. They run before you make a choice on our site, and our cookie choices do not apply to them; they follow beehiiv’s privacy policy (www.beehiiv.com/privacy).

Accessibility tool. If you use the accessibility tool on our website (provided by accessiBe), it may save your settings in your browser so they stay in place as you move between pages.

Your choices. In the United States and most other places, we do not show a notice. Analytics and Google’s advertising features are on, and session replay is off, until you change them with the “Your Privacy Choices” link at the bottom of every page. In the learning portal, the “Cookie settings” item in your account menu opens the same choices.

If your device is set to a time zone in the European Union or elsewhere in Europe, in Quebec or in Ontario, or hides its time zone, we ask first on our website and course page. No analytics, session replay or advertising cookie of ours is used until you choose (the newsletter form’s own tools are described above), and “Reject all” is as easy as “Accept all”. The learning portal does not show this notice: there, no analytics or advertising cookie of ours is used until you choose with the “Cookie settings” link at the bottom of the page or in your account menu, or until a choice you made on our website or course page carries over.

You can change your choice at any time with the “Your Privacy Choices” link at the bottom of every page (it reads “Cookie settings” where we ask first). There you can turn “Analytics”, “Session replay” (website and course page only) and “Advertising” on or off one by one. Your choice covers all three sites. We keep it for up to 12 months. If your browser deletes your saved choice (some, like Safari, do after 7 days without a visit), choose again; Global Privacy Control keeps advertising off automatically. Where we ask first, we ask again. In California, the “Your Privacy Choices” link shows the California opt-out icon, and the panel it opens says: “California residents: turn off Advertising, or use Global Privacy Control, to opt out of the sale or sharing of your personal information.”

Global Privacy Control. If your browser sends a Global Privacy Control signal, we treat it as a request to opt out of the sale or sharing of your personal data. We turn advertising off, even if you allowed it before, and a note next to the link at the bottom of the page reads “Opt-out signal honored”. You can still turn advertising back on yourself in your privacy choices.

When analytics is off. Google Analytics may still receive basic signals that use no cookies, for example that a page was viewed. Google uses them to estimate traffic.

Our own page counts. We also count page views ourselves, without cookies. We keep only daily totals by site, page, referring website, campaign tags, device type (phone, tablet or computer) and country. We work out the country from your IP address, and we do not keep the IP address.

A record of your choice. When you make a choice, or when we apply a Global Privacy Control signal, we keep a record of it: a random ID (also saved in your ecc_consent cookie), what you allowed, the date, which of our sites you were on and your country. It does not include your IP address, your name or your account.

The cookies we use.

1. ecc_consent, set by us. Remembers your cookie choice. Kept up to 12 months.
2. Sign-in cookies (names start with “sb-”), set by us in the learning portal. Keep you signed in. Kept until you sign out, at most 400 days.
3. ecc_2fa_session, set by us in the learning portal. Shows you entered the sign-in code we emailed you. Kept until you close your browser.
4. ecc_2fa_device, set by us in the learning portal, only if you tick “remember this device”. Kept 30 days.
5. ecc_email_link, ecc_setup_link, ecc_setup_ref, x-auth-ok, x-user-role and x-session-valid, set by us in the learning portal. Make sign-in links and account setup work safely. Kept from 30 seconds to 1 hour.
6. _cfuvid, set by Cloudflare on our website. Security. Kept until you close your browser.
7. cf_clearance, __cf_bm, _pxvid, _px3 and pxcts, set on beehiiv.com by our newsletter sign-up form and its security providers (Cloudflare and HUMAN). Protect the form from bots. Kept from 30 minutes (or until you close your browser) up to 1 year.
8. _ga and _ga_ followed by an ID, set by Google Analytics. Analytics. Kept up to 2 years.
9. attribution_data, set by beehiiv on our website, only when analytics is on. Remembers how you found our site (campaign tags, ad click IDs, the page you came from), so newsletter sign-ups can be credited. Kept 30 days.
10. _clck and _clsk (on our website and course page) and MUID, CLID and others (on clarity.ms), set by Microsoft Clarity, only with session replay on. Session replay. Microsoft decides how long they are kept.
11. Google’s own cookies and identifiers, set by Google, only while advertising is on. Used for Google signals. Google decides how long they are kept.

9. Children’s privacy.

The Website is not marketed to or intended for visitors under age 18. We do not knowingly collect any personal data from any individual 13 years of age or under.

10. International Website visitors.

The Website is intended for users located in the United States AND IS NOT INTENDED FOR USERS IN THE EUROPEAN UNION OR OTHER FOREIGN COUNTRIES OR REGIONS. If you are accessing our Website from outside United States of America, please be aware that your personal data may be transferred to, stored, and processed in the United States where the servers we use are located at our sole discretion. Please be aware that the data protection and other laws of the United States may not be as comprehensive as those in your country/region. We will take steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

11. Changes to the Privacy Policy.

We will review and may update this Privacy Policy from time to time. Updates to the Privacy Policy will be placed on this web page. This Privacy Policy was last updated on the above date.

12. How to contact us.

If you have any questions about this Privacy Policy or our practices regarding your personal data, please do not hesitate to contact us.

Email us at: info@elizabethcconsulting.com
Call us: 804-512-1883

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