Privacy Policy
Updated May 25, 2018
This Naked Mind, LLC (inclusive of This Naked Mind™ and The Alcohol Experiment™) is committed to protecting your privacy. This privacy policy (this “Privacy Policy”, the “policy”) applies to your use of the www.thisnakedmind.com, learn.thisnakedmind.com, www.alcoholexperiment.com and www.thisnakedmindcommunity.com websites (the “website”, the “site”), and the This Naked Mind and The Alcohol Experiment iOS Mobile apps (the “app”, which is also governed by the privacy and terms referred to as the “site” below), which is owned and operated by This Naked Mind, LLC (“This Naked Mind”, “TNM”, “us”, “our”, “we”). We take the responsibility of protecting your privacy seriously, and are required to comply with various obligations under privacy laws. Any information collected by This Naked Mind, LLC from this site may be used in accordance with this policy.

I. Collection and Use of Personal Information
This Naked Mind, LLC may collect personal information from you. Personal information is information relating to an identifiable person who can, by virtue of such information, be directly or indirectly identified. You may be asked to provide your personal information anytime you are in contact with This Naked Mind, LLC. This Naked Mind, LLC and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

II. What personal information we collect
When you create a This Naked Mind, LLC user account by signing up for our free content, purchasing a program, joining one of our communities, or contacting us, we collect a variety of Personal Data including but not limited to first and last name, email address, mailing address, gender, age, country, state, Facebook information, postcode, university as well as information about your alcohol consumption and wellbeing. When payment, or payment information, is required, we will direct you to submit credit card information through a third-party such as Stripe, Braintree or PayPal. (Payment details are held by our third-party processor, not This Naked Mind, LLC.)

III. How we use Your personal information
The personal information we collect allows us to keep you updated on This Naked Mind, LLC’s latest product announcements and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by navigating to the unsubscribe link in the last email you received from This Naked Mind, LLC.

We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes.

We may use your personal information to verify identity, assist with identification of users, and to determine appropriate services.

From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with This Naked Mind, LLC, you may not opt out of receiving these communications.

We may also use personal information for internal purposes such as auditing, data analysis, and research to improve This Naked Mind, LLC’s products, services, and customer communications.

IV. Collection and Use of Non-Personal Information
We also collect data in a form that does not identify any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
We may collect information such as language, zip code, area code, unique device identifier, referrer URL, and the time zone where a This Naked Mind, LLC product is used so that we can better understand customer behavior and improve our products, services, and advertising.

We may collect information regarding customer activities on any of our websites. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is non personal information.

We may collect and store details of how You use our services. This information may be used to improve the relevancy of results provided by our services.

V. Cookies and Other Technologies
This Naked Mind, LLC’s websites, e-mail messages, and advertisements may use “cookies” and other technologies such as tracking, re-marketing tags, and pixels based on context, e.g., a search query, a channel you are reading, or inferred interests. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non personal information. We design and target advertising based on how you interact with This Naked Mind, LLC. If you do not wish to receive ads targeted to your interests from This Naked Mind, LLC, you can choose to limit ad tracking, which will opt your This Naked Mind, LLC ID out of receiving such ads regardless of what device you are using. You may still see ads based on context like a search query or a channel you are reading. This Naked Mind, LLC and our partners also use cookies and other technologies to remember how you use our website and software. Our goal in these cases is to make your experience with This Naked Mind, LLC more convenient and personal, and provide you better customer service. To limit ad tracking, you may opt-out by clicking on this tool for (USA) or this tool for (EU) both of which are not directly This Naked Mind, LLC-affiliated. You may also use your browser’s settings to disable cookies and other tracking tools. Please note that certain features of the This Naked Mind, LLC website will not be available once cookies are disabled. Click here for more information on the This Naked Mind, LLC cookies policy.

We gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. This Naked Mind, LLC may use this information in our marketing and advertising services.

In some cases we use a “click-through URL” linked to content on the This Naked Mind, LLC website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our marketing communications. We also use it to account for Affiliate activity and pay Affiliate commissions and bonuses.

VI. Disclosure to Third Parties
At times This Naked Mind, LLC may make certain personal information available to strategic partners that work with This Naked Mind, LLC to provide products and services, or that help This Naked Mind, LLC market to customers. Personal information will only be shared by This Naked Mind, LLC to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

Affiliates. This Naked Mind, LLC will provide your email address to affiliates or users who refer you to us, or through whom you create a This Naked Mind, LLC account.

Service Providers. This Naked Mind, LLC shares personal information with companies who provide services such as information processing, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, and assessing your interest in our products and services. This Naked Mind, LLC also shares your information with financial institutions who provide payment (both to and from you) services.

Advertising. This Naked Mind, LLC shares personal information with social media advertising platforms for the purpose of custom audience generation and the development of targeting criteria for other audiences.

Legal. It may be necessary − by law, litigation, or requests from government authorities within or outside your country of residence − for This Naked Mind, LLC to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.

Corporate Change. Additionally, in the event of a reorganization, merger, or sale of This Naked Mind, LLC we may transfer any and all personal information we collect to the relevant third party.

VII. Protection of Personal Information
This Naked Mind, LLC takes the security of your personal information very seriously. When your personal data is stored by This Naked Mind, LLC, we have implemented security policies and technical measures to safeguard the Personal Data we collect from accidental loss, destruction or damage and unauthorized access, use and disclosure. When you use some This Naked Mind, LLC products and services that by their nature are public facing, such as when you post on a This Naked Mind, LLC forum, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if You list your name and email address in a forum posting, that information is public. Please take care when using these features.

VIII. Retention of Personal Information
This Naked Mind, LLC will retain your personal information for as long as you have a This Naked Mind, LLC account. After your This Naked Mind, LLC account is terminated, we will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

IX. Access to Personal Information
This Naked Mind, LLC will provide you with access to your Personal Data (including a copy) upon your request. We may decline to process requests that are frivolous, vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by contacting compliance@thisnakedmind.com.

X. Children & Education
This Naked Mind, LLC is intended for adult use only. We understand the importance of taking extra precautions to protect the privacy and safety of children. Children under the age of 18, are not permitted to create their own This Naked Mind, LLC account; instead, a parent must obtain the account and provide the parent’s information to This Naked Mind, LLC. If we learn that we have collected the personal information of a child under 18 we will delete the information as soon as possible.

XI. Third Party Sites and Services
This Naked Mind, LLC websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

XII. Your Rights Under the GDPR
If you are a citizen or a resident of a country in the European Union, the GDPR grants you the following rights:

a. Access to Your Personal Data. You have the right to receive a copy of your personal data that is subject to processing by This Naked Mind, LLC. Ordinary requests will be granted without charge to you within one calendar month of when you make the request. In cases of excessive, unreasonable, or repeated requests This Naked Mind, LLC may charge you a reasonable fee and may require additional time to grant your request. Also, This Naked Mind, LLC may use reasonable means to confirm your identity before granting any request for data so as to prevent granting fraudulent requests. To request a copy of your personal data, please contact us by email at compliance@thisnakedmind.com.

b. To have Your Data Corrected. If Your personal data is erroneous or outdated, You have the right to have it corrected. To do so, please contact This Naked Mind, LLC via email at compliance@thisnakedmind.com.

c. To be Forgotten. You have the right to be forgotten by This Naked Mind, LLC. You may exercise this right by emailing us at compliance@thisnakedmind.com. We will comply with your request, at no charge to you, within one calendar month by deleting your account, along with all of your personally-identifiable data that is subject to any This Naked Mind, LLC processing. Naturally, after we grant your request you will not have access to any This Naked Mind, LLC products or services unless and until you open a new This Naked Mind, LLC account. This Naked Mind, LLC may use reasonable means to confirm your identity before granting any request for data so as to prevent the granting of fraudulent requests.

d. To Restrict Processing of Your Data. You can request that your data not be processed via This Naked Mind, LLC partners. You can make that request by emailing us at compliance@thisnakedmind.com and, if you wish, you can even specify which third parties to restrict from processing your data. We will respond to your request, at no charge to you, within thirty (30) days from when you make your request. Please be advised that some of our partners, e.g., Stripe, Braintree, PayPal, etc., are essential to This Naked Mind, LLC services, so that if you block processing by them, This Naked Mind, LLC’ services may be unavailable to You.

XII. Our Company-wide Commitment to Your Privacy
To make sure your personal information is secure, we communicate our privacy and security guidelines to This Naked Mind, LLC employees and strictly enforce privacy safeguards within the company.

XIV. Privacy Questions
If you have any questions or concerns about This Naked Mind, LLC’s Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at compliance@thisnakedmind.com. When a privacy question or an access or download request is received we have a team dedicated to addressing the specific concern or query which you are seeking to raise. In responding to your request, we may need to request more information from you. If you are unsatisfied with the response you receive, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances. If you live in the European Economic Area, United Kingdom, or Switzerland, and you wish to contact us regarding questions or to exercise your statutory rights, please contact us at compliance@thisnakedmind.com.

XV. Updates to the Policy
This Naked Mind, LLC reviews it’s privacy practices on an ongoing basis, and as such, may update this Privacy Policy from time to time. Please check this page periodically to ensure you are familiar with its current content.
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