At InnerTrek Services ("InnerTrek"), we respect the privacy of others. This PRIVACY POLICY ("Privacy Policy") explains InnerTrek’s privacy practices with respect to the newport-academy.com website (together with its features and services, the "Site"). This Privacy Policy also provides an overview of the following:

• The type of information about you InnerTrek collects through the Site;
• How InnerTrek collects such information;
• How InnerTrek uses such information;
• Who will have access to such information; and
• InnerTrek’s security measures for protecting such information.

This Privacy Policy only applies to information collected through the Site. InnerTrek has additional privacy and security policies related to certain of its operations, such as its Oregon Health Authority policies and procedures.

Carefully read each and every term and condition of this Privacy Policy in its entirety. By visiting, accessing, or using the Site, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the Site’s Terms of Use, and your continuing visit, access or use of the Site reaffirms your acceptance and agreement of the foregoing in each instance.

As used herein, the term "personal information" means information that would allow someone to contact you physically or online, including, for example, your name, physical address, telephone number, e-mail address, or social security number; and the term "non-personal information" means any information other than personal information that InnerTrek may collect from you.

A Special Note About Minors

The Site is a general audience website intended for use by adults over 21. The Site is not designed or intended to attract, and is not directed to, adults under the age of twenty one (21), children under eighteen (18) years of age, let alone children under thirteen (13) years of age. InnerTrek does not collect personal information through the Site from any person it actually knows to be under thirteen (13) years of age. If InnerTrek obtains actual knowledge that it has collected personal information through the Site from a person under thirteen (13) years of age, then it will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under twenty one (21) years of age, then you (or your parent or legal guardian) may at any time request that InnerTrek remove content or information about you that is posted on the Site. Please submit any such request ("Request for Removal of Underage Information") to any one of the following:

By e-mail: hello@innertrek.org, with a subject line of "Request for Removal of Underage Information."

For each Request for Removal of Underage Information, please state "Request for Removal of Underage Information" in the e-mail subject line, and clearly state the following in the body:

a. The nature of your request; b. The identity of the content or information to be removed; c. Whether such content or information is found on the Site; d. The location of the content or information on the Site (e.g., providing the URL for the specific web page the content or information is found on); e. That the request is related to the "Request for Removal of Underage Information;" f. Your name, street address, city, state, zip code, and e-mail address.

InnerTrek is not responsible for failing to comply with any Request for Removal of Underage Information that is incomplete, incorrectly labeled, or incorrectly sent.

Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Site. Also, please note that InnerTrek is not required to erase or otherwise eliminate, or to enable erasure or elimination of, such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule, or regulation requires InnerTrek to maintain the content or information; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished, or reposted by the third party); when InnerTrek anonymizes the content or information so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of InnerTrek's voluntary practices concerning the collection of personal information through the Site from certain minors and individuals under the age of twenty one (21) and is not intended to be an admission that InnerTrek is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

Categories of Information Collected

InnerTrek may collect personal and non-personal information about you through the Site.

Categories of Information Collected Through the Site

The categories of personal and non-personal information collected from you through the Site might include:

• Your first, last, and/or middle name;
• A client’s (or a prospective client’s) first, last, and/or middle name;
• Your personal contact information (e.g., mailing address, e-mail address, telephone number);
• A client’s (or a prospective client’s) personal contact information (e.g., mailing address, e-mail address, telephone number);
• Your gender;
• A client’s (or a prospective client’s) gender;
• Your date of birth;
• A client’s (or a prospective client’s) date of birth;
• Your electronic signature;
• Your insurance information (e.g., the primary subscriber’s name, contact information, date of birth, and/or insurance member identification number, the primary subscriber’s name, contact information, and/or date of birth, and the insurance company’s name and contact information);
• A client’s (or a prospective client’s) insurance information (e.g., the primary subscriber’s name, contact information, date of birth, and/or insurance member identification number, the primary subscriber’s name, contact information, and/or date of birth, and the insurance company’s name and contact information);
• The name and/or location of the school(s) where you attend;
• The name and/or location of the school(s) where a client (or a prospective client) attends;
• Billing, payment, or shipping information (e.g., payor or payee name, checking account number, credit card number, expiration date, verification code, accountholder name, cardholder name, billing address, mailing address, tax ID number);
• Business contact information (e.g., company, title, mailing address, e-mail address, telephone number, facsimile number, tax ID number);
• Computer, mobile device, and/or web browser information (e.g., IP address, mobile device ID information, operating system, browser type, referring/exist web pages, web page requests, cookie information, hardware attributes, software attributes);
• Third-party website, network, platform, server, and/or application information (e.g., Facebook, LinkedIn);
• Usage activity concerning your interactions with the Site and/or third-party websites, networks, platforms, servers, or applications accessed through the Site (e.g., number of clicks on a page or feature, amount of time spent on a page or feature, identity of third-party websites, networks, platforms, servers, and applications being accessed through the Site);
• Transactional information, including but not limited to enrollment or pre-enrollment submissions, insurance verifications or applications, payments, and comments, feedback, and/or other communications made in or through the Site;
• Information set forth in the Site’s online enrollment or pre-enrollment forms, online insurance verification forms, and/or online contact or communication forms; and/or
• Information about content and/or communications that you submit to or publish on or through the Site.

Categories of Other Information Collected From Your Mobile Device

If you use your mobile device to visit, access, or use the subscription or members-only area of the Site, then additional categories of personal and non-personal information collected from you through the Site might include:

• Your name associated with your mobile device;
• Your address associated with your mobile device;
• Your telephone number associated with your mobile device;
• Your geolocation;
• Your mobile device ID information;
• With your express agreement, your mobile contacts and/or contact information (e.g., names, telephone numbers, physical addresses, e-mail addresses, photos); and/or
• With your express agreement, information about third-party software applications on your mobile device (including, without limitation, general software apps, and online social media apps).

How Information is Collected

InnerTrek might collect personal and non-personal information from you when you register with or subscribe to the Site (e.g., by subscribing to InnerTrek regular or promotional e-mail lists through the Site); complete and submit any online enrollment, pre-enrollment, insurance verification, and/or contact us forms; when you allow the Site to access, upload, download, import, or export content found on, or to otherwise interact with, your computer or mobile device (or any other device you may use to visit, access, or use the Site) or online accounts with third-party websites, networks, platforms, servers, or applications (e.g., your online social media accounts, your cloud drives and servers, or your mobile device service provider); when you send InnerTrek an e-mail; and/or when you visit, access, or use the subscription or members-only area of the Site.

In addition, if you or a third party sends InnerTrek a comment, message or other communication (such as, by way of example only, an e-mail, text message, fax, letter, phone call, or voice message) about or referencing you or your activities in or through the Site, then InnerTrek may collect any personal or non-personal information provided therein or therewith.

Also, InnerTrek might use various tracking, data aggregation, and/or data analysis technologies, including, for example, the following:

• Cookies, which are small data files (e.g., alphanumeric identifiers) that InnerTrek may transfer to your device to collect information about your use of the Site. Cookies may store information about your account, including, without limitation, your account ID, login password, purchase history, and user preferences, which allows InnerTrek to provide you with a more personalized experience. You may set your device’s browser to reject cookies, or to notify you when a cookie is set, but if you reject or delete cookies, then you may not have access to all features, functions, or pages of the Site. InnerTrek does not use cookies to collect information from children under thirteen (13) years of age;
• Web beacons, which are pieces of code embedded in the Site that collect information about users of the Site. Web beacons may be used, without limitation, to count visitors to the Site, to monitor how users navigate the Site, and to count how many e-mails that were sent were actually opened;
• Mobile analytics to understand the functionality of the Site and/or the subscription or members-only area of the Site on your phone. Mobile analytics may record information such as, without limitation, how often you use the Site or the subscription or members-only area of the Site, the events that occur within the Site and/or the subscription or members-only area of the Site, aggregated usage, performance data, and where the Site and/or the subscription or members-only area of the Site were downloaded from;
• Information from your mobile device’s address book or contact list, which is collected with your express permission to connect you with other users of the Site;
• Information from your mobile device’s general and online social media apps, which is collected with your express permission to provide you with more personalized advertising and promotional content; and
• Google Analytics, which is a web analytics tool that helps InnerTrek understand how users engage with the Site. Google Analytics uses cookies and similar technologies to collect and analyze information about the Site’s users and/or to compile activity reports. Google Analytics may also collect information regarding the use of other websites, apps, and online resources. For more information about Google Analytics, please visit: https://policies.google.com/technologies/partner-sites.

Additionally, InnerTrek might supplement the information collected from you with information that is publicly available and/or that InnerTrek receives from third parties, including, without limitation, third parties under contract with InnerTrek to provide services to you. For example, if you access the Site through a third-party website, application, or log-in (e.g., Facebook, LinkedIn), you may allow InnerTrek to have access to certain information in your third-party site profile. This may include, without limitation, your first and last name, e-mail address, photo, birthday, gender, and other information in your third-party site profile. If you don’t want to InnerTrek to collect this information, you must change the privacy settings on your third-party site profile.

Use of Information Collected

InnerTrek may use the personal and/or non-personal information it collects from you through the Site for any of the following purposes:

To operate the Site and/or the subscription or members-only area of the Site;

• To process any transactions you make through the Site;
• To send you information, newsletters, promotional materials, and other offerings from InnerTrek;
• To send you information, newsletters, promotional materials, and other offerings from InnerTrek’s business partners;
• To notify you about any promotions, contests, and sweepstakes offered by InnerTrek and/or its business partners;
• To fulfill and process your requests for InnerTrek’s services and/or offerings;
• To personalize your user experience with the Site and/or the subscription or members-only area of the Site;
• To respond to your comments, questions, and/or concerns;
• To provide you with the applicable products, services, and/or information you request;
• To improve the Site and/or the subscription or members-only area of the Site;
• To improve the products, services, and/or information InnerTrek makes available through the Site;
• To monitor the usage of the Site;
• To enforce the Site’s Terms of Use;
• To protect the rights and/or property of InnerTrek and/or its third-party business partners; and
• To protect the rights, property, and/or safety of InnerTrek’s users and/or other third parties.

When possible, InnerTrek uses information in an anonymous or aggregated format.

Sharing of Information Collected

InnerTrek may share the personal and/or non-personal information it collects from you through the Site under the following circumstances:

• When required by any applicable international, federal, state, or local law, rule, or regulation;
• In response to a request from law enforcement authorities or other government officials;
• When InnerTrek believes such disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• With InnerTrek’s third-party business partners;
• With InnerTrek’s third-party vendors who provide InnerTrek with services, provided that such third-party vendors use the personal and/or non-personal information only for the purpose of providing those services to InnerTrek;
• With InnerTrek’s third-party advertisers and marketing partners, provided that such third parties use the personal and/or non-personal information only for the purpose of providing advertising and marketing services to InnerTrek;
• With any company or other legal entity owned or controlled by InnerTrek, owned or controlled by any person or entity that also owns or controls InnerTrek, or that owns or controls InnerTrek;
• With a third party in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of InnerTrek’s assets;
• To enforce the Site’s Terms of Use;
• To protect the rights and/or property of InnerTrek and/or its third-party business partners; and
• To protect the rights, property, and/or safety of InnerTrek’s users and/or other third parties.

When possible, InnerTrek shares information in an anonymous or aggregated format.

All information voluntarily provided by you through telephone calls with InnerTrek’s customer service and/or enrollment center may be used and shared as set forth above.

Access to Information Collected

If you would like to review, correct, and/or update the personal information that you have provided to InnerTrek through the Site, then you may contact InnerTrek’s support team at: hello@innertrek.org.

Data Retention

InnerTrek will retain your personal information for as long as it is needed to fulfill the purposes for which InnerTrek collected the information, including, without limitation, for the purposes of satisfying any legal, accounting, or reporting requirements.

Data Security

InnerTrek uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. InnerTrek cannot, however, ensure or warrant the security of any information you transmit to InnerTrek, and you do so at your own risk. Once InnerTrek receives your transmission of information, InnerTrek makes commercially reasonable efforts to ensure the security of such information on InnerTrek’s systems.

Please note that the Site and/or the subscription or members-only area of the Site may contain links to other websites, networks, platforms, servers, and/or applications. These linked sites are not under InnerTrek’s control. InnerTrek is not responsible for the privacy or security practices of these linked sites or any information you provide to them.

Changes to this Privacy Policy

InnerTrek reserves the right to change this Privacy Policy at any time and from time to time without notice. All such changes will be posted on the Site. By visiting, accessing, or using the Site after InnerTrek posts such changes, you agree to the most-recent version of this Privacy Policy. You are responsible for regularly reviewing this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, then please contact InnerTrek’s support team at hello@innertrek.org.

This Privacy Policy was last updated on: July 22, 2024

Effective Date: July 22, 2024

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