With the following Privacy Policy, we (that is me and the third parties involved) would like to give you as a "data subject" an overview of the processing of your Personal Information by me, Nneka Anuligo of 1718 Capitol Ave, Cheyenne, WY 82001 United States acting as the Data Controller.  

This Privacy Policy applies to Personal Information that I collect from my clients and from my website, social media group, and other online users (hereinafter “you”), as well as information that I collect automatically during your visits to my website (e.g., information collected via cookies).  

For purposes of this Privacy Policy, “Personal Information” means any data, such as your name, telephone number, email address, IP (“Internet Protocol”) address or location data.   I recognize the legislative ambiguity around Wyoming State and US Federal Privacy Law, and in the absence of the former, have voluntarily committed to the Data Protection Principles as set out in the General Data Protection Regulation (“GDPR”).  

Information I collect

I may ask you for Personal Information when you:

• Use my website, social media presences and services,

• Request services, support, or information,

• Participate online or otherwise in marketing activities including Affiliate Marketing,

• Subscribe to my programs, marketing and promotional emails or other materials,

• Interact with me on third-party social networking sites (subject to the terms of use and privacy policies of said third parties); or

• Contact me.

Categories of Personal Information I collect may include your name, email address, address, contact telephone numbers. It may also include Personal Information such as your job title and other business or company information. I may also collect demographic data, such as age, gender, your interests, and preferences. I may also ask you for other information that I need to process payment for my services.  

In order to provide you with a more consistent and personalized user experience in your interactions with me, data collected through one source may also be linked to other data collected by me through other sources. This may include data that helps me to identify you when you access my websites through several different devices. I may also enrich the data I collect with data obtained from other parties, such as my business partners or other third parties, to create individual profiles about you. Examples of how I may use this data include using it to improve your user experience when visiting my website, and to display options tailored to your preferences.  

For more information about my use of cookies and similar tracking technologies, including how to opt out of targeted advertising and marketing, please contact me.

My use of Personal Information

I may use your Personal Information for the following purposes:  

• Providing you with solutions, services, and support, and conducting transactions you request,

• Sending notifications to you, including information about the status of your transaction, including information about the services as well as order confirmations, about specific programs in which you may wish to participate, about solutions and services available,

• Enabling you to use my website, Providing support to respond to your inquiries,

• Customize, analyze, and optimize my solutions, services (including content to gauge usage trends and determine the effectiveness of my marketing and affiliate marketing campaigns), technologies, notifications, and business relationships with you,

• Better understanding my clients and website users,

• Personalizing content and implementing your preferences,

• Enforcing my terms and conditions, and separate contracts (if any) with you,

• Prevention of fraud and other prohibited or unlawful activities,

• Protecting the security and integrity of my websites, businesses, and services; and

• Other functions and purposes disclosed to you at the time of collection or as required or permitted by law.

Legal basis for processing

My legal basis for collecting and using your Personal Information as described in this Privacy Policy depends on the Personal Information involved and the specific context in which I collect it. Generally, your Personal Information will be collected and processed by me on one or more of the following legal bases:  

Your consent, for example, where I have obtained your consent to process your Personal Information for certain activities. You are free to withdraw your consent at any time by contacting me. If you withdraw your consent, the lawfulness of any processing based on your prior consent prior to its withdrawal will not be affected. Where applicable, I will ask you for your consent to process your Personal Information at the time you provide it to me.

Compliance with contractual obligations. At the time of collection, I will inform you whether providing your Personal Information is mandatory and what the consequences will be if you do not provide your information.

To comply with my legal obligations where other laws require me to process your Personal Information (e.g., Wyoming`s commercial and tax laws) or where I need your Personal Information to protect your essential interests or those of another person.

On the basis of my legitimate interests, this includes providing this website and/or relevant services and/or carrying out marketing activities, provided always that your interests or fundamental rights and freedoms do not outweigh my legitimate interests.

If you have any questions or need more information about the legal basis for the collection of your Personal Information, please contact me.  

Data Automatically Collected

I may automatically collect information about user behavior and usage regarding your visits of my website, such as the pages you view, the links you click, and other actions you take in connection with my website.  

I may also collect certain information about the browser you use to access my website, such as your IP address, device identifier, location data, browser type and language, and your access times, the URL ("Uniform Resource Locator") of the website from which you arrived at my website, and the URL to which you are directed after leaving my website if you clicked on a link on my website.  

Data from third party sources

I may obtain data about you from third-party sources, such as marketing partners, social networks, and other third parties. I may use this data to better analyze your user behavior to improve my ability to provide you with relevant marketing information and services, and to prevent and combat fraud.  

Retention of your data

I will retain your Personal Information as necessary in connection with the purposes described in this Privacy Policy, for as long as you are actively working with us, and in accordance with Wyoming`s Retention Periods as set out in 021-4 Wyo. Code R. § 4-3 and other applicable laws.  

International transfers

I may transfer your Personal Information to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your Personal Information may be transferred to countries outside the United States. In order to provide adequate protection for your Personal Information when it is transferred, I have contractual arrangements regarding such transfers. I take all reasonable technical and organizational measures to protect the Personal Information I transfer.  

Sharing of Personal Information

I may share your Personal Information with affiliates and business partners for the purposes described in this Privacy Policy, including, without limitation, to carry out transactions you request or to respond more quickly to your needs. My affiliates and/or business partners may contact you with information about services and offerings. I will only share your Personal Information with affiliates and business partners who have agreed to protect your Personal Information and to use it only for the purposes I have specified.  

In addition, I may disclose your Personal Information: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; or if I have reason to believe that disclosure is necessary to protect my business, and my clients or the public.  

In all cases other than those described above, Personal Information will not be disclosed without your consent.  

Social Media

I am present on social media on the basis of my legitimate interest. If you contact me via social media platforms, you should note that the chat history can neither be deleted by me nor by you. And that, in accordance with the GDPR, I and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement.  

A Joint Controller Agreement itself is very legalistic and lengthy, but in a nutshell, it clarifies how the jointly responsible parties will fulfill the obligations arising from data protection laws that are applicable to them. The legal basis for the use of the relevant social media platform is my legitimate interest, your consent or, in the case of a (pre) contractual relationship with us, the initiation of a contractual service, if any.  

Entresoft

I also use the Entresoft LLC system to process user data and do lead management. Your details may be stored in the Enteresoft system, and I may use your Personal Information in connection with the services offered to me by Entresoft including marketing, to fulfill my contractual obligations to you or to carry out pre-contractual measures.  

Updating your information

If you believe that the information, I hold about you is inaccurate or that I`m no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting me.  

Access Request and updating your Personal Information

In the event that you wish to make a Data Subject Access Request, you may inform me in writing of the same. I will respond to requests regarding access and correction as soon as reasonably possible. Should I not be able to respond to your request within thirty (30) days after receiving your request, I will inform you in writing within thirty (30) days of the time by which I will be able to respond to your request. If I`m unable to provide you with any Personal Information or to make a correction requested by you, I shall generally inform you of the reasons why I`m unable to do so (except where I`m not required to do so under the respective legal regulations mentioned above).    

Your rights

You can exercise the following rights:

Right to information

Right to rectification

Right to object to processing

Right to deletion

Right to information

Right to data portability

Right of objection

Right to withdraw consent

Right to complain to a supervisory authority

Right not to be subject to a decision based solely on automated processing.

Please contact me at any time with questions and suggestions regarding data protection and to enforce your rights. If you have any questions about the nature of the Personal Information I hold about you, or if you wish to request the erasure or rectification of Personal Information I hold about you, or to exercise any of your other rights, please contact me.  

How I protect your Personal Information

I will take all reasonable steps to protect your Personal Information from misuse, alteration, and loss, and from unauthorized access, alteration, or disclosure. To this end, I use the following means, among others:  

Use of encryption when collecting and transmitting sensitive data such as credit card information, technical and organizational measures to ensure the continuous integrity, availability and fail-safety of processing systems and services,

Restricting physical access to data I collect about you,

Restricting online access to data I collect about you,

Ensuring appropriate safeguards are in place and those of my business partners to ensure the security of your Personal Information; and, where required by law, deleting, or anonymizing Personal Information.

Collection and Use of Children's Personal Information

I take the privacy of children very seriously. I do not knowingly collect Personal Information from children through my website.  

Changes to this Privacy Policy

I may update this privacy policy from time to time. If I make changes to this Privacy Policy or materially change my use of your Personal Information, I will revise this Privacy Policy accordingly and also change the effective date at the end of this section. I encourage you to periodically review this Privacy Policy to be informed of how I use and protect your Personal Information.  

Contacting

If you would like to contact me regarding my privacy practices or for any other reason, please use [email protected] or call me on +1 (702) 745-2644.

This Policy is effective as of Thursday, February 2, 2023.