Privacy Policy

This Privacy Policy is effective as of September 2023.

Assemblage LLC, DBA Kommas with Kellé and all of its subsidiaries, recognizes that your privacy is important. This Privacy Policy is designed to explain how we collect, use, share, and protect the personal information you provide to us when you access our website, purchase our goods or services, or engage with us on social media, as well as your own rights to the information we collect. These terms ensure compliance with the General Data Protection Regulation (GDPR). 

Please read this Privacy Policy carefully. If you do not want your information processed in accordance with this Privacy Policy, you are prohibited from using or accessing this site. We will alert you to any changes to this policy by changing the “last updated” date at the top of this policy. Any changes become effective immediately upon publication on our website, and you waive specific notice of any changes to the policy by continuing to use and access our site(s). We encourage you to review this Privacy Policy periodically when you use our website for any purpose or engage with us on social media. You are deemed to have accepted any changes to any revised Privacy Policy by your continued use of our website after the revised Privacy Policy is posted.

INFORMATION WE COLLECT

We collect a variety of information from you when you visit our website, make purchases, interact with us on social media and in order to better provide you with services to include but not limited to speaking engagements, accounting, business advising, membership and masterclasses. By accepting this Privacy Policy, you are specifically consenting to our collection of the data described below, to our use of the data, to the processing of this data, and to our sharing of the data with third-party processors as needed for our legitimate business interests.

A) PERSONALLY IDENTIFIABLE INFORMATION 

Personally Identifiable Information (PII) is information that can be used to identify you specifically. This information includes your name, shipping address, email address, telephone number, or demographic information like your age, gender, or hometown. You consent to giving us this information by providing it to us entirely voluntarily on our website. You provide some of this information when you register with or make purchases from our website. You may also provide this information by participating in various activities associated with our site, including responding to blogs, contacting us with questions, or participating in group services. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website, services or from making purchases.

B) USAGE DATA

Usage Data is collected automatically when using our website.

Usage Data includes information such as:

Your device’s IP address, browser type, browser version, operating system, the dates and times that you access our website, and the specific pages you view.

Details of your visit to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website.

Usage Data collection may also include data collected by third-party service providers, such as advertising and analytics providers. Usage Data collected by third-party service providers generally does not identify a specific individual. Usage Data collection by third parties may include:

Email Confirmations: We may receive email confirmations when you open an email from us. This allows us to determine if users are responding favorably to our email communications and to improve those communications.

Other Technologies: Other data technologies may be used that collect comparable information for security, fraud detection, and similar purposes, to give us information about your use of our website, and to greatly improve our website and service offerings to you.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. When you first encounter our website, you will be asked to “accept cookies.” If you wish to disable cookies, you may do so through your individual browser options. We also use cookies and web beacons to store certain information. We may use cookies to authenticate your identity, to determine if you are logged onto our website, for personalization, for security, for targeted advertising, or for analysis of the performance of our website and services. For example, cookies allow us to recommend blog posts to you based on what you have read on our site in the past. We use cookies that are not specific to your account but unique enough to allow us to analyze general trends and use, and to customize your interaction with our website. If you choose to reject all cookies some parts of our Site may not work properly in your case.

Web Beacons. Pages of our website [and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.

C) FINANCIAL DATA

Financial data is data that is related to your payment method, such as credit card or bank transfer details.

We collect financial data in order to allow you to purchase, order, return, or exchange products or services from our website and any related mobile apps. We store limited financial data. 

D) SOCIAL NETWORKING DATA

We may access personal information from social networking sites and apps, including but not limited to Facebook, Instagram, LinkedIn, Twitter, Snapchat, or other social networking sites or apps not named specifically here, which may include your name, your social network username, location, email address, age, gender, profile picture, and any other public information. If you do not want us to access this information, please go to the specific social networking site and change your privacy settings.

E) MOBILE DEVICE DATA

If you use our website via a mobile device, we may collect information about your mobile device, including device ID, model and manufacturer, and location information.

HOW WE COLLECT, USE, PROCESS INFORMATION AND USER CHOICES

We do not collect any PII about you unless you voluntarily provide it to us. However, you may be required to provide certain PII to us when you elect to use certain products or services available on the Site. These may include: (a) registering for an account or our email list; (b) entering a sweepstakes or contest sponsored by us or one of our partners/affiliates; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting a form or transmitting other information by telephone or letter; or (e) submitting your credit card or other payment information when ordering and purchasing products and services. When processing certain information, such as payment information with affiliated banking institutions or payment processors, we encrypt the transaction, using Secure Socket Layer (SSL) encryption technology, in order to prevent your PII from being stolen or intercepted. 

We may, from time to time, send you emails regarding new products and services that we feel may interest you. In addition, if you indicate upon registration that you are interested in receiving offers or information from us and our partners, we may contact you by direct mail, email, telephone calls, SMS, or other equivalent forms of electronic communication occasionally about products and services that may be of interest to you. Only Company (or agents working on behalf of Company and under confidentiality agreements) will send you these solicitations, and only if you have previously indicated that you wish to receive them. If you do not want to receive solicitations from us, you can “opt-out” at any time.

The information we collect and store is used primarily to allow us to offer goods and services for sale. In addition, we may collect, use, and process your information based on the following grounds:

LEGITIMATE BUSINESS INTERESTS

We may use and process your data for our legitimate business interests, which include, among other things, communicating with you, improving our goods or services, improving our website, and providing you with the information or products that you have requested.

Performance of a Contract. We may use and process your information to enter into a contract with you and to perform our contractual obligations to you.

Consent. We may use your data, or permit selected third parties to use your data, based on your consent to our use and sharing of that data. You may withdraw your consent at any time, but doing so may affect your ability to use our website or other offerings.

ACCESS RIGHTS TO DATA

Your California Privacy Rights. Beginning on January 1, 2005, California Civil Code Section 1798.83 permits customers who are California residents to request certain information regarding our disclosure of personal information for their direct marketing purposes. To make such a request, please contact us via the information below. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserves its right not to respond to requests submitted other than to the address specified in this paragraph.

California’s privacy laws require a company to provide notice to California users of their rights to receive information on to which entities their information was shared for marketing purposes.

SECURITY OF YOUR PII

We will exercise all reasonable efforts to safeguard the confidentiality of customer personal information both on the Website and offline. 

For example:

• We work hard to ensure that the data we collect is reliable, accurate, complete and current. We encrypt all PII, in order to prevent unauthorized parties from viewing such information when it is transmitted to us. We also only keep collected information only for as long as reasonably necessary and use it only for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
• We limit access to PII only to specific employees, contractors and agents who have a reasonable need to come into contact with your information. 
• We employ a number of physical, electronic, and procedural safeguards to protect PII. Our secure servers and our data centers are protected by industry-standard encryption, and our servers reside behind firewalls and employ high-level password protection.
• Access by you to your PII is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone.
• Credit card transactions and order fulfillments are handled by established third party banking institutions and processing agents Stripe and Quickbooks. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

Consequently, we shall not be liable for unauthorized disclosure of personal information due to no fault of including, but not limited to, errors in transmission and unauthorized acts of Assemblage LLC, DBA Kommas with Kellé, all of its subsidiaries and third-parties. By transmitting any such information to us, you accept that you do so at your own risk.

RELEASE OF INFORMATION

We will not sell, trade, or rent your PII to others. We do provide some of our product and service offerings through contractual arrangements made with affiliates, service providers, partners and other third parties (“Service Partners”). We and our Service Partners may need to use some PII in order to perform tasks between our respective sites, or to deliver products or services to you. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this Site; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us provide customer service.

We will encourage our Service Partners to adopt and promote strong privacy policies. However, the use of your PII by our Service Partners is governed by the respective privacy policies of those providers, and is not subject to our control. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other Sites accessible through this Site, including our Advertising and Service Partners, have their own privacy policies and data collection, use and disclosure practices. Please consult each Site’s privacy policy. We are not responsible for the policies or practices of third parties.

DISCLOSURE TO THIRD-PARTIES

The following are specific reasons why we may share your information:

Third Party Processing: We may disclose your information to third parties who assist us with various tasks, including payment processing, hosting services, email delivery, communications, and customer service. We may not always disclose these third-party processors if not required by law. We do not authorize them to use or disclose your personal information except in connection with providing our company with their services.

By Law: We may share your data as required by law or to respond to legal process, including a subpoena, or as necessary to protect the rights, property, and safety of others. This includes sharing information with other parties to prevent or address fraud and to avoid credit risks.

To Protect Our Company: We may use your information to protect our company, including to investigate and remedy any violations of our rights or policies. We may also disclose your information as reasonably necessary to acquire and maintain insurance coverage, manage risks, obtain financial or legal advice, or to exercise or defend against legal claims.

Business Transfers: In the unlikely event our company engages in a merger, acquisition, bankruptcy proceedings, dissolution, reorganization, or similar transaction or proceeding, we may transfer or share your data as part of that proceeding. In such transitions, customer information is one of the business assets that is acquired by a third party. You acknowledge that such business transfers may occur and that your personal information can continue to be stored, used, or processed as otherwise set forth in this privacy policy.

Advertisers: We may use third-party advertising companies to run and manage our ads, such as but not limited to Facebook, LinkedIn and Instagram to produce ads that appear when you visit our website. These companies may use information about your visit to our website and other websites that are contained in web cookies to offer you personalized advertisements about goods and services that might interest you. We cannot control the activities of such other advertisers or websites. You should consult the respective Privacy Policies of these third-party advertisers for more detailed information on their practices as well as for instructions about how to opt-out of certain practices. Please note that, at this time, we do not recognize automated browser signals regarding tracking systems, which may include “do not track” instructions.

Other Third Parties: We may share information with advertisers, our investors, or other third parties for the purpose of conducting general business analysis. If we do so, we will make reasonable efforts to inform you if required by law.

Interaction With Others: If You interact with others on our website, such as participating in a group chat or a group online course, other users may have access to some of your data, including your name, profile picture, and your history of interaction with our website, such as prior comments or posts.

Online Postings: When you post online, your posts may be viewed by others, and we may distribute your comments outside the website.

External Links: Our website may include hyperlinks to other websites not controlled by us. We suggest you exercise caution when clicking on a hyperlink. Although we use reasonable care in including a hyperlink on our own web page, we do not regularly monitor the websites of these third parties and are not responsible for any damage or consequences you suffer by using these hyperlinks. We are not bound by the Privacy Policies of any third-party website that you access by a hyperlink, nor are they bound by ours. We encourage You to read the Policies of those third-party websites before interacting with them or making purchases. They may collect different information and by different methods than we do.

Other Purposes: We may disclose your personal data as necessary to comply with any legal obligation or to protect your interests, or the vital interests of others or our company.

WEBSITE ANALYTICS

We may partner with third-party analytic companies, including WordPress and Google. The analytic companies may also use cookies or other tracking technologies to analyze visitors’ use of Our Website to determine the popularity of the content, and better understand online activity. We do not transfer personal information to these third-party vendors. However, in order to access Our Website, You must consent to the collection and use of your information by these third-party analytic companies. You should review their Privacy Policy and contact them directly if You have questions. If You do not want any information to be collected and used by tracking technologies, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

Google Analytics: You can opt-out of having your activity on Our website made available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents Google Analytics from retrieving information about your visits to Our website. For more information about Google’s Privacy Policy, please visit: https://policies.google.com/privacy.

Facebook: You can opt-out of Facebook’s interest-based ads by visiting: https://www.facebook.com/help/568137493302217. You can learn more about Facebook’s Privacy Policy at: https://www.facebook.com/full_data_use_policy.

PROCESSING YOUR INFORMATION

For the most part, we do not process your information in-house, but give it to third-party processors for processing. For example, when Stripe takes your payment information, they are a third-party processor. They process your payment and remit the funds to us. In many instances, it will be necessary for us to transmit your information to a third-party processor, as we do not have the capability to perform these functions. 

HOW LONG WE KEEP YOUR DATA

We retain personal data for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, we will retain your information for the purpose of complying with its legal and audit obligations, and for backup and archival purposes. For example, we will retain certain personal information indefinitely for the purposes of maintaining your account, unless and until you delete your account.

Note that we cannot control the retention policies of third parties. If you wish to have any third parties, including those to whom we have transmitted your data, delete that data, you will need to contact those third parties directly. You may request from Us a list of all third parties to whom We have transmitted your data.

We may retain usage data (data that is gathered by our company or third-party analytics companies for the purpose of analyzing the use of our Website) as needed for internal analysis purposes. This type of data is usually retained for a shorter period of time than personal data, unless the data is necessary to improve the security or functionality of our Website or offerings, or we are legally obligated to retain the data for a longer period of time.

CHILDREN

This Website is not designed for use by children under age 18, and We do not knowingly solicit personal data from anyone under age 18. If You are under age 18, do not access or use Our Website or related products or services. If You become aware that We have collected data of anyone under the age of 18, please contact Us so that We may delete that data.

YOUR RIGHTS

You have certain rights with respect to your personal data, as outlined below. Note that we may charge you a reasonable fee for actions that you ask us to take with respect to your data. In addition, we reserve the right to request that you provide us with evidence of your identity before We take any action with respect to the exercise of your data rights. Further, your rights may be restricted or nullified to the extent they conflict with our compelling business interests, the public interest, or the law.

Update account information. You have the right to update or change any information you have provided to ys. To update or delete your information, please contact us.

Confirm personal data and its use. You have the right to request that we confirm what data We hold about You, and for what purposes. You also have the right to confirm whether we process your data or deliver your data to third-party processors, and for what purposes. We will supply you with copies of your personal data unless doing so would affect the rights and freedoms of others.

Change consent: You have the right to change your consent to our use of your information. In such cases, we may require you to delete your account with us, as described above, and you may not have full access to our website.

Request a copy of data: You have the right to request a digital copy of the data that we hold about you. Your first request for a copy of your personal data will be provided free of charge; subsequent requests will incur a reasonable fee.

Transfer your data: You have the right to request that we gather and transfer your data to another controller, in a commonly used and machine readable format, unless doing so would cause us an undue burden.

Delete all data: You have the right to request that we delete all data that we hold about you, and we must delete such data without undue delay. There are exceptions to this right, such as when keeping your data is required by law, is necessary to exercise the right of freedom of expression and information, is required for compliance with a legal obligation, or is necessary for the exercise or defense of legal claims. Such a request may result in a termination of your account and/or services with us and you may have limited or no use of our website.

Emails and communications: You may opt out of receiving future email correspondence from us by checking the appropriate box at the bottom of the email. You may change your communication settings by contacting us at info@kommaswithkelle.com.

Marketing communications: You may opt out of receiving any third-party marketing communications or having your personal information used for marketing purposes. You may do this by contacting us at info@kommaswithkelle.com

Processing: You may, in some circumstances, restrict the processing of your data, such as when you contest the accuracy of your data or when you have objected to processing, pending the verification of that objection. When processing has been restricted, we will continue to store your data but will not pass it on to third-party processors without your consent, or as necessary to comply with legal obligations or protect your rights or those of others or our company. In addition, you may opt out of any processing of your data altogether. Note, however, that doing so may result in the termination of your account and loss of access to our Website.

Complaints: If you are an EU resident, you have the right to complain to a supervising authority if you believe We are misusing Your data or have violated any of your rights under this Privacy Policy or applicable law. You may do so in the EU member state in which you reside or have your place of business or in which the alleged infringement took place. If you are located outside the EU, you may have rights under privacy laws in the jurisdiction where you live.

Transfer of Information Across National Borders: Our site and various information we collect are operated on servers located in various jurisdictions, including the United States. When you access or use the Site and/or our services, personal information about you may be transferred outside the country in which you are situated to these other locations. The Company’s policies ensure that such personal information is protected to the same standard when processed by any Company entity or office around the world. We also ensure that appropriate contracts containing standard data protection clauses approved by the European Commission to protect that information and the rights of individuals are in place with any and all third-party service providers we may use.

NEWSLETTER PRIVACY

We offer the opportunity for you to volunteer certain information to us that is used for email and marketing purposes. This information includes, but is not limited to, your name and email. You will have an opportunity to unsubscribe from any future communications via email, but we reserve the right to maintain a database of past email subscribers. 

If you have any questions, concerns or inquiries about our Privacy Policy, or our use of your PII, or our privacy practices, please contact us via: 

Email: info@kommaswithkelle.com

Or

Regular mail: 4491 Cheshire Station Plaza, Suite 2007, Dale City, VA 22193