Last Updated 3 January 2023
Privacy Policy
We at Business Atelier and Cumul Inc. (“Business Atelier and Cumul Inc.,” “we,” “us,” or “our”) have
created this privacy policy (this “Privacy Policy”) because we know that you care about how information
you provide to us is used and shared. This Privacy Policy applies to our information collection and use
practices in connection with: (i) our websites, including, without limitation, businessatelier.co,
businessatelier.mykajabi.com (the “Websites”); and (ii) the information you provide to us offline,
including, without limitation, via phone and email.
Description of Users and Acceptance of Terms
This Privacy Policy applies to visitors to the Websites, who view only publicly-available content
(“Visitors”), and users who register with us (“Registered Users”) and wish to purchase a product or
service through one of our Website.
By visiting any of our Websites Visitors are agreeing to the terms of this Privacy Policy and the
accompanying Terms of Use.
By registering with us and purchasing a product or service through one of our Website, each
Registered User is agreeing to the terms of this Privacy Policy, the accompanying Terms of Use.
By providing us information offline, you are also agreeing to the terms of this Privacy Policy.
Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of
Use and the Terms and Conditions of Purchase.
GDPR and Privacy Shield Notice
Natural persons located in the European Economic Area (“EEA”) should review the General Data
Protection Regulation (“GDPR”) and GDPR Privacy Shield Notice here.
In addition, the Privacy Shield Notice should be reviewed if your personal information is transferred
from the EEA or Switzerland to the US, pursuant to the E.U.-U.S. or Swiss-U.S. Privacy Shield.
The Information We Collect/or Receive; the Purpose of Collection and Use
In the course of operating the Websites and/or interacting with you, we will collect (and/or receive) the
following types of information.
1. Contact Information
When you sign up to receive any of our newsletters, respond to a survey, register for a masterclass,
webinar, VIP Week Day, purchase any product or service, or sign up to become our affiliate partner,
you may be required to provide us with certain information about yourself, such as your name, address,
e-mail address, address, social media information, phone number, PayPal address (only if you sign up
to become our affiliate partner) and SSN#/Tax ID# (only if you sign up to become our affiliate partner)
(the “Contact Information”). The Contact Information is used to provide the requested product or service
or information and to contact you for purposes of direct marketing of our current and future products
and services.
If you land on one of our pages through an affiliate partner link and provide us Contact Information
(e.g., to request information, purchase a product or service), we may share your name and e-mail
address to such affiliate partner to let him/her know that you were referred and in case (s)he has
offered you any bonuses or rewards for following their referral link. We have no control over how
affiliate partners may use your information after it has been received and we are not responsible for
fulfilling any bonuses that such affiliate partners may have offered you; where applicable, please check
such affiliate partners’ privacy policies and terms of use for more information on how they may use your
personal information.
2. Order Information
When you place an Order, you must provide us with certain information about the products and
services you are seeking to purchase. Such information is collectively called the “Order Information.”
The Order Information is used to fulfill your Order.
3. Billing Information
When you wish to purchase a product or service, you will be required to provide certain information in
addition to the Personal Information and Order Information noted above. Such information may include
a debit card number, credit card number, expiration date, billing address, activation codes, and similar
information. Such information is collectively called the “Billing Information.” Billing Information is
collected and processed by our third-party payment processor operating as our agent (see, Onward
Transfers to Third Parties). We do not directly obtain or process any Billing Information.
4. Other Information
“Other Information”). Such Other Information may include:
a. From You. Additional information about yourself that you voluntarily provide to us (e.g., via a
survey), such as household income range, gender, product and service preferences, and other
information that does not identify you personally.
b. From Your Activity. Information that we automatically collect when you use the Websites,
including, without limitation:
- IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Websites you visit; and similar data; and
- Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.
data that a website stores on your computer’s or mobile device’s hard drive so that your computer will
“remember” information about your visit. We may use both session cookies (which expire once you
close your web browser) and persistent cookies (which stay on your computer until you delete them) to
help us collect Other Information and to enhance your experience using the Websites. If you do not
want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer
or mobile device. Please consult your Internet browser’s documentation for information on how to do
this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the
Websites may not function properly.
d. Third-Party Analytics. We use third-party analytics services (such as Google Analytics) to evaluate
your use of the Websites, compile reports on activity, collect demographic data, analyze performance
metrics, and collect and evaluate other information relating to the Websites and mobile and Internet
usage. These third parties use cookies and other technologies to help analyze and provide us the
data. By accessing and using the Websites, you consent to the processing of data about you by these
analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised
that if you opt out of any service, you may not be able to use the full functionality of the Websites.
Below is a list of analytics providers that we use; however, such list may be subject to change based on
how we wish to understand the user experience and we will endeavor to update it diligently. You may
use the accompanying links to learn more about such providers and, if available, how to opt-out from
their analytics collection.
For Google Analytics, please visit: https://www.google.com/analytics
For Vimeo, please visit: https://vimeo.com/privacy
e. From Other Sources. We also may collect or receive information from third parties, such as
Facebook and/or other third-party social media sites.
Information Collected by or Through Third-Party Advertisers/Remarketers
We may share Other Information about you with third parties, including, but not limited to, advertising
and remarketing providers, or other brand partners, for purposes of personalizing or otherwise
understanding how you engage with ads or other content. These third parties may use cookies, pixel
tags (also called web beacons or clear gifs), or other technologies to collect Other Information in
furtherance of such purposes, including to tailor, target (i.e., behavioral, contextual, retargeting, and
remarketing), analyze, report on, and/or manage advertising campaigns or other initiatives. For
example, when a browser visits a site, pixel tags enable us and these third-parties to recognize certain
cookies stored within the browser to learn which ads or other content bring a user to a given site. In
addition, we may receive Other Information from these third parties, including through their service
providers, such as advertising identifiers, IP addresses, and post-conversion data.
Below is a list of advertising/remarketing providers that we use; however, such list may be subject to
change based on the campaigns that we run and we will endeavor to update it diligently. You may use
the accompanying links to learn more about such providers and, if available, how to opt-out from their
targeted ads or other personalization features. Please note you will not necessarily be opted-out of
advertising or content generally; you may still receive generic ads or content.
For Facebook and Instagram, please visit: https://www.facebook.com/privacy/policy
For Google, please visit: https://support.google.com/ads/answer/2662922?hl=en
In addition, you may opt-out of interest-based advertising by participating providers by
visiting http://www.networkadvertising.org and http://www.aboutads.info/choices for details on how to
do so.
Information Collected Through the Websites that is Not Covered by this Privacy Policy
You may post and/or share information, including but not limited to, comments using forums and other
similar features available through the Websites. NONE of the information you provide using these
features is protected by this Privacy Policy. THIS PRIVACY POLICY DOES NOT APPLY TO ANY
INFORMATION (INCLUDING PERSONAL INFORMATION) THAT YOU PROVIDE USING ANY SUCH
FEATURES. ALL SUCH INFORMATION IS PUBLIC INFORMATION AND MAY BE SEEN,
COLLECTED OR USED BY ANY USER OF THE WEBSITES. Please note that if you post and/or share
information on our Websites through your Facebook account, such information will be subject to
Facebook’s privacy policy.
You also recognize that prior results do not guarantee a similar outcome. Thus, the results obtained by others – whether clients of the Company or otherwise – applying the principles set out in this Website are no guarantee that you or any other person or entity will be able to obtain similar results.
Information Collected Through the Facebook Community Group
You may post and/or share information through our Facebook Community Group. THIS PRIVACY
POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION)
THAT YOU PROVIDE USING THE FACEBOOK COMMUNITY GROUP. USE OF THE FACEBOOK
COMMUNITY GROUP IS GOVERNED BY FACEBOOK’S PRIVACY POLICY. ALL SUCH
INFORMATION IS PUBLIC INFORMATION AND MAY BE SEEN, COLLECTED OR USED BY ANY
USER OF OUR FACEBOOK COMMUNITY GROUP.
Aggregate Data
In an ongoing effort to better understand our visitors, customers, and our products and services, we
may analyze the Order Information and Other Information in aggregate form in order to operate,
maintain, manage, and improve the Websites and/or our products and services. This aggregate
information does not identify you personally. We may share this aggregate data with our affiliates,
agents, and business partners. We may also disclose aggregated user statistics in order to describe
our products and services to current and prospective business partners and to other third parties for
other lawful purposes.
Additional Uses
We also use information collected pursuant to this Privacy Policy to provide our services; to process
Orders; to administer our rewards and promotional programs; to maintain and improve our Websites
and services to you; to solicit your feedback; and to inform you about our products and services and
those of our third-party marketing partners.
Sharing with Third Parties
Like many businesses, we contract with other companies to perform certain business-related services.
We may disclose your information, including personal information in some cases, to certain types of
third-party companies, but only to the extent needed to enable them to provide such services, including,
without limitation, technical assistance, order fulfillment, customer service, marketing assistance,
payment processing, survey collection, promotional and marketing assistance, and business
operations. These other companies will have access to your information, including personal information
in some cases, only as necessary to perform their functions and to the extent permitted by law. We
may also disclose your information, including any personal information, to any of our parent companies,
subsidiaries, affiliates, joint ventures, or other companies under common control with us in order to
support delivery of our products and services.
Business Transfer
In the event of a merger, dissolution, or similar corporate event or the sale of all or substantially all of
our assets, we expect that the Information that we have collected and/or received, including personal
information, would be transferred to the surviving entity in a merger or to the acquiring entity. All such
transfers shall be subject to our commitments with respect to the privacy and confidentiality of such
personal information as set forth in this Privacy Policy.
Disclosures to Public Authorities
In certain situations, we may be required to disclose personal data in response to lawful requests by
public authorities, including to meet national security or law enforcement requirements. We may also
disclose personal information to other third parties when compelled to do so by government authorities
or required by law or regulation including, but not limited to, in response to court orders and
subpoenas.
Opt-Out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by
e-mailing the instructions to this email address: hello@businessatelier.co Please allow us a reasonable
time to process your request.
Accessing and Modifying Personal Information and Communication Preferences
Upon request to hello@businessatelier.co, we will provide you with confirmation as to whether we are
processing your personal information, and have the data communicated to you within a reasonable
time. You have the right to correct, amend, or delete your personal information where it is inaccurate or
has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee
to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries
and requests.
In addition, you may manage your receipt of marketing and non-transactional communications by
clicking on the “unsubscribe” link located on the bottom of any Business Atelier marketing email.
Customers cannot opt out of receiving transactional e-mails related to their account or their Orders.
We will use commercially reasonable efforts to process such requests in a timely manner. You should
be aware, however, that it is not always possible to completely remove or modify information in our
subscription databases.
Information You Share on Public Forums
We feature or may in the future feature public forums such as message boards or web logs, webinars,
classes, telephone conferences, or coaching calls, user comments, chat rooms, and similar activities
(collectively, “Public Forums”). You may voluntarily post and share information through such Public
Forums. NONE of the information you provide to through the Public Forums or through use of these
features are protected by this Privacy Policy including any personal information. THIS PRIVACY
POLICY DOES NOT APPLY TO ANY INFORMATION (INCLUDING PERSONAL INFORMATION)
THAT YOU PROVIDE USING ANY SUCH FEATURES. ALL SUCH INFORMATION IS PUBLIC
INFORMATION AND MAY BE VIEWED, COLLECTED, USED, MODIFIED AND/OR DISCLOSED FOR
ANY PURPOSE BY US, ANY USER OF THE PUBLIC FORUM, AND THE PUBLIC.
You should think carefully before disclosing any information in any Public Forum.
How We Protect the Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized
access, disclosure, alteration, or destruction, taking into account the risks involved in processing and
the nature of such data, and in compliance with applicable laws and regulations. Please understand,
however, that no security system is impenetrable. We cannot guarantee the security of our databases,
nor can we guarantee that the Information that you supply will not be intercepted while being
transmitted to and from us over the Internet. In particular, e-mail sent to or from the Websites may not
be secure, and you should therefore take special care in deciding what information you send to us via
e-mail.
Retention of Personal Information
We will retain your personal information in a form that identifies you only for as long as it serves the
purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized,
or as allowed under applicable law.
Important Notice to Non-U.S. Residents
It is important to note that the Websites and their servers are operated in the United States. If you are located outside of the U.S., please be aware that any information provided to or collected by us,
including personal information, will be transferred from your country of origin to the U.S. Except in the
case of data transfers under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework,
your decision to provide such data to us, or allow us to collect such data through our Websites,
constitutes your consent to this data transfer.
Children
We do not knowingly collect personal information from children under the age of 13 through the
Websites. If you are under 13, please do not give us any personal information. We encourage parents
and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by
instructing their children to never provide personal information through the Websites without their
permission. If you have reason to believe that a child under the age of 13 has provided personal
information to us, please contact us, and we will endeavor to delete that information from our
databases.
California Residents
Business Atelier does not monitor, recognize, or honor any behavioral advertising opt-out or do not
track mechanisms, including general web browser “Do Not Track” settings and/or signals.
California residents should review their specific rights under the California Consumer Privacy Act
(CCPA).
External Websites
The Websites may contain links to third-party websites. We have no control over the privacy practices
or the content of any of our business partners, advertisers, sponsors, or other websites to which we
provide links. As such, we are not responsible for the content or the privacy policies of those third-
party websites. You should check the applicable third-party privacy policy and terms of use when
visiting any other websites.
Changes to This Privacy Policy
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change
this Privacy Policy from time to time. By accessing the Websites and/or using our services after we
make any such changes to this Privacy Policy, you are deemed to have accepted such changes.
Please be aware that, to the extent permitted by applicable law, our use of the Information is governed
by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy
Policy on a regular basis.
How to Contact Us
If you have questions about this Privacy Policy, please contact us via: Email: hello@businessatelier.co
