PRANA COUNSELING SERVICES, LLC
PRIVACY POLICY
This privacy policy sets out how Prana Counseling Services, LLC (“Prana”) uses and
protects any information that you give Prana when you use this website. The privacy
policy is meant to help you understand what information we collect, why we collect it,
and how you can update or delete your information.
Prana is committed to ensuring that your privacy is protected. Should we ask you to
provide certain information by which you can be identified, then you can be assured
that it will only be used in accordance with this privacy statement. Prana may change
this policy from time to time by updating this page. You should check this page from
time to time to ensure that you are happy with any changes. This policy was last
updated on February 13, 2019.
OUR COMMITMENT TO INDIVIDUAL PRIVACY
Prana is committed to protecting the privacy and accuracy of your information. We do
not share your personal information and we collect the least amount of personally
identifiable information required to provide you with requested services.
Prana does not request and we ask that you not send us any sensitive information (e.g.,
government-issued identification numbers, racial or ethnic information, political
opinions, religious affiliations, health, biometrics or genetic characteristics, criminal
background). If you choose not to provide requested personal information, you can still
visit most Prana web pages, but you might be unable to access certain services that
require our interaction with you.
WHAT WE COLLECT
We collect a variety of information that you provide directly to us. In general, we collect
information from you through:
• Using any of our services
• Uploading or posting to public forums associated with Prana
• Submitting requests or questions to us via forms or e-mail
• Requesting customer support and technical assistance
We may collect the following information:
PRANA COUNSELING SERVICES, LLC
• Payment information, and/or shipping information.
• Name, address, telephone number, and e-mail address
• Information, such as your age, job, professional affiliation, and other personal
information
• Information you provide to us in connection with any application process,
including, for example, educational and work experience, prerequisite
knowledge, any pre-assessment you complete, your goals, and other information
• User-generated content you upload or post to public forums through our
services
• Any other information you choose to directly provide to us in connection with
your use of our services
Please note, we will never ask for your social security number.
INFORMATION WE COLLECT THROUGH AUTOMATED MEANS
Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard
drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets
you know when you visit a particular site. Cookies allow web applications to respond to
you as an individual. The web application can tailor its operations to your needs, likes
and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze
data about web page traffic and improve our website in order to tailor it to customer
needs.
Overall, cookies help us provide you with a better website, by enabling us to monitor
which pages you find useful and which you do not. A cookie in no way gives us access
to your computer or any information about you, other than the data you choose to
share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept
cookies, but you can usually modify your browser setting to decline cookies if you
prefer. This may prevent you from taking full advantage of the website.
Analytics Information
PRANA COUNSELING SERVICES, LLC
When you use our services, we and our service providers (which are third-party
companies that work on our behalf) may use cookies, and similar technologies to track,
collect and aggregate certain information including, among other things, which pages
of our website(s) were visited, the order in which they were visited, when they were
visited, the URLs from which you linked to our website(s), and which hyperlinks were
“clicked.” Collecting such information may involve logging the IP address, operating
system and browser software used by each user of the website. Through such
information, we may be able to determine from an IP address a user’s Internet Service
Provider and the general geographic location (city/state) of his or her point of
connectivity.
We also use or may use these technologies to help us determine and identify repeat
visitors, the type of content and sites to which a user of our website(s) links, the length
of time each user spends at any particular area of our website(s), and the specific
functionalities that users choose to use.
We use third-party web analytics services (such as those of Google Analytics) on our
website(s) to collect and analyze usage information through cookies and similar tools;
engage in auditing, researching, or reporting; assist with fraud prevention; and provide
certain features to you. We also provide a limited amount of your information (such as
your e-mail address and order history) to our marketing agency partners so that they
can analyze website usage on our behalf, which allows us to improve our services.
We may also use third-party customer relationship management software (like
Infusionsoft), as a medium for communications, either through e-mail, or through
messages about our services (software usage providers (like Google Analytics); financial
services (like independent accountants, tax preparers, bookkeepers, and QuickBooks);
and independent contractors (like team members in marketing, management, software
development).
If you have questions about other third-party service provider’s collection of your
information for this purpose, please contact us. For more information about our use of
cookies and similar technologies, including how you can install the Google Analytics
Opt-out Browser Add-on to prevent Google from using your information for analytics,
or otherwise control or disable cookies, please see
PRANA COUNSELING SERVICES, LLC
https://tools.google.com/dlpage/gaoptout. Your choice to opt out of Google Analytics
will in no way affect your ability to receive Prana services.
Online Advertising
We may allow third party companies, including advertising companies (such as Google,
Facebook, Instagram, etc.), to place cookies on our website. These cookies enable such
companies to track your activity across various sites where they display ads and record
your activities so they can show ads that they consider relevant to you as you browse
the Internet. These Cookies store information about the content you are browsing
together with an identifier linked to your device or IP address.
These Cookies also allow us and third parties to know whether you’ve seen an ad or a
type of ad, and how long it has been since you’ve last seen it. This information is used
for frequency capping purposes, to help tailor the ads you see, and to measure the
effectiveness of ads. For more information about online advertising and how you can
control or disable these cookies, please see:
• Cookie settings in Internet Explorer (http://windows.microsoft.com/engb/windows7/how-to-manage-cookies-in-internet-explorer-9)
• Cookie settings in Firefox (http://support.mozilla.org/en-US/kb/cookies)
• Cookie settings in Chrome
(https://support.google.com/chrome/answer/95647?hl=en)
• Cookie settings in Safari Mac (http://support.apple.com/kb/PH5042) and iOS
(http://support.apple.com/kb/HT1677)
If you only want to limit third party advertising cookies, you can turn such cookies off by
visiting the following links:
• Your Online Choices (http://www.youronlinechoices.com/uk/)
• Network Advertising Initiative (http://www.networkadvertising.org/)
• Digital Advertising Alliance (http://www.aboutads.info/consumers)
Do Not Track Signals
Currently, we do not monitor or take any action with respect to web browser signals or
other mechanisms for the expression of choice regarding collection of information
about an individual over time and across third-party web sites or online services (e.g.,
Web browser “do not track” signals).
PRANA COUNSELING SERVICES, LLC
WHAT WE DO WITH THE INFORMATION WE GATHER
We require this information to understand your needs and provide you with a better
service, and in particular for the following reasons:
• Send you information in connection with the services offered
• Respond to your communications and requests
• Contact you by e-mail, postal mail, or phone (including via SMS messages)
regarding Prana services, surveys, research studies, promotions, special events
and other subjects that we think may be of interest to you
• Customize the content we provide through our services
• Help us better understand your interests and needs, and improve our services
• Comply with any procedures, laws, and regulations which apply to us where it is
necessary for our legitimate interests or the legitimate interests of others
• Establish, exercise, or defend our legal rights where it is necessary for our
legitimate interests or the legitimate interests of others
• Internal record keeping
AGGREGATE / ANONYMOUS DATA
We may aggregate and/or anonymize any information collected through the website(s)
so that such information can no longer be linked to you or your device
(“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous
Information for any purpose, including without limitation for research and marketing
purposes, statistical analyses of website(s) usage, and may also share such data with any
third parties, including advertisers, promotional partners, and sponsors.
DATA SUBJECT RIGHTS AND YOUR CHOICES
You may have certain rights with respect to your information as further described in this
section.
Your Legal Rights
If you would like further information in relation to your legal rights under applicable law
or would like to exercise any of them, please contact us using the information in the
“PRANA Contact Information” section below at any time. Your local laws may permit
you to request that we:
• Provide access to and/or a copy of certain information we hold about you
• Prevent the processing of your information for direct-marketing purposes
(including any direct marketing processing based on profiling)
PRANA COUNSELING SERVICES, LLC
• Update information which is out of date or incorrect
• Delete certain information which we are holding about you
• Restrict the way that we process and disclose certain of your information
• Transfer your information to a third-party provider of services
• Revoke your consent for the processing of your information
We will consider all requests and provide our response within the time period stated by
applicable law. Please note, however, that certain information may be exempt from
such requests in some circumstances, which may include if we need to keep processing
your information for our legitimate interests, to comply with a legal obligation, or if
necessary for the performance of a contract involving you or us.
To the extent that you make such a request, we require certain information to help
verify your request and prevent fraudulent information and removal requests.
Specifically, we ask that you provide the following pieces of information:
- Username and e-mail address associated with your user account(s)
- Approximate date of user account registration
- Information you want to view and/or request removed
- A statement under penalty of perjury that all information in your request is
truthful and that this is your user account or that you have the authorization to
make the request on behalf of the owner of the user account
Depending on the circumstances and the information you request, we may require
additional methods of verification in our discretion.
MARKETING COMMUNICATIONS
You may instruct us not to use your contact information to contact you by e-mail, postal
mail, or phone regarding services, promotions and special events that might appeal to
your interests by contacting us using the information below. In commercial e-mail
messages, you can also opt out by following the instructions located at the bottom of
such e-mails. Please note that, regardless of your request, we may still use and share
certain information as permitted by this Privacy Policy or as required by applicable law.
For example, you may not opt out of certain operational e-mails, such as those
reflecting our relationship or transactions with you.
SOCIAL MEDIA
PRANA COUNSELING SERVICES, LLC
Prana does not require that users disclose user names or passwords for a user’s
personal social media account, nor does Prana require users to access personal social
media in our presence or divulge any personal social media information to us.
THIRD PARTY LINKS AND FEATURES
Our website(s) may contain links to third-party websites such as social media sites, and
also contain third-party integrations (such as the Facebook “Like” button) and
functionalities. If you choose to use these sites or features, you may disclose your
information not just to those third-parties, but also to their users and the public more
generally depending on how their services function. Prana is not responsible for the
content or practices of those websites or services. The collection, use, and disclosure of
your information will be subject to the privacy policies of the third-party websites or
services, and not this Privacy Policy. We urge you to read the privacy and security
policies of these third-parties.
JURISDICTION AND CROSS-BORDER TRANSFER
Your personally identifiable information may be stored and processed in any country,
including the United States, where we have facilities in which we engage third-party
service providers, and by requesting Prana services you consent to the transfer of
information to countries outside of your country of residence which may have data
protection rules that are different from those of your country. In certain circumstances,
courts, law enforcement agencies, regulatory agencies or security authorities in those
other countries may be entitled to access your personally identifiable information.
CHILDREN’S PRIVACY
Prana is intended for general audiences and not for children under the age of 18. If we
become aware that we have inadvertently collected “personal information” (as defined
by the United States Children’s Online Privacy Protection Act) from children under the
age of 13 without legally-valid parental consent, we will take reasonable steps to delete
it as soon as possible. We also comply with other age restrictions and requirements in
accordance with applicable local laws.
HOW WE PROTECT YOUR INFORMATION
We consider the confidentiality and security of your information to be of the utmost
importance. Prana takes a variety of technical, administrative, and physical measures to
protect your information from disclosure to or access by third parties. In order to
PRANA COUNSELING SERVICES, LLC
prevent unauthorized access or disclosure, we have put in place suitable physical,
electronic and managerial procedures to safeguard and secure the information we
collect online.
Please note that we do not guarantee the security of information, as no method of
internet transmission or storage is completely secure. Also note that we may retain and
store your information in our databases and systems even after your Prana account is
deactivated as long as we have a legitimate purpose to do so and in accordance with
applicable law.
We intend to take reasonable and appropriate steps to protect the information that you
share with us and/or third-party service providers from unauthorized access or
disclosure. We will contact you within 72 hours after first becoming aware of any data
breach that is likely to result in a risk to your rights or freedoms. If you have reason to
believe that your interaction with us is no longer secure, please immediately notify us by
e-mail at info@innovativeotsolutions.com or by phone +1 (970) 416-8612.
CONTROLLING YOUR PERSONAL INFORMATION
You may choose to restrict the collection or use of your personal information in the
following ways:
• Whenever you are asked to fill in a form on the website, look for the box that you
can click to indicate that you do not want the information to be used by anybody
for direct marketing purposes
• If you have previously agreed to us using your personal information for direct
marketing purposes, you may change your mind at any time by writing to or emailing us at alison@prana-counseling.com
We will not sell, distribute or lease your personal information to third parties unless we
have your permission or are required by law to do so. We may use your personal
information to send you promotional information about third parties which we think you
may find interesting. You will have the choice to opt out from receiving this
promotional information.
CHANGING, UPDATING, OR DELETING PERSONAL INFORMATION
PRANA COUNSELING SERVICES, LLC
If you believe that any information we are holding on you is incorrect or incomplete,
please write to or e-mail as soon as possible, at the above address. We will promptly
correct any information found to be incorrect.
If you would like to request to review, correct, update, suppress, restrict, or delete
personally identifiable information that you have previously provided to us, or if you
would like to request to receive an electronic copy of your personally identifiable
information for purposes of transmitting it to another company (to the extent this right
to data portability is provided to you by applicable law), you may contact us by e-mail at
info@innovativeotsolutions.com. We will respond to your request consistent with
applicable law.
In your request, please make clear what personally identifiable information you would
like to have changed, whether you would like to have your personally identifiable
information suppressed from our database or otherwise let us know what limitations you
would like to put on our use of your personally identifiable information. For your
protection, we will only implement requests with respect to the personally identifiable
information associated with the particular e-mail address that you use to send us your
request, and we may need to verify your identity before implementing your request. We
will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes
and/or to complete any transactions that you began prior to requesting a change or
deletion. There may also be residual information that will remain within our databases
and other records, which will not be removed.
CHANGES TO OUR PRIVACY POLICY
Please note that we review our privacy practices from time to time, and that these
practices are subject to change. Any change, update, or modification will be effective
immediately upon posting on our Website(s). You can know if the Privacy Policy has
changed since the last time you reviewed it by checking the “Effective Date” included
at the beginning of the document. If we make a material change to the Policy, you will
be provided with appropriate notice in accordance with legal requirements. By
continuing to use our services, you are confirming that you have read and understood
the latest version of this Privacy Policy. Be sure to return to this page periodically to
ensure familiarity with the most current version of this Privacy Policy.
PRANA COUNSELING SERVICES, LLC
PRANA CONTACT INFORMATION
If you have any questions, comments or complaints about this Privacy Policy, please
contact us:
E-mail: alison@prana-counseling.com
Prana Counseling Services, LLC
204 Walnut Street, Suite D
Fort Collins, CO 80524
970.402-7029