LAST UPDATED: Friday, May 25, 2018
Thank you for visiting SubtleWordsThatSell.com (hereinafter “Website,” “Site”), owned, operated and controlled by Ghita Services, Inc., a California company (hereinafter, “Company,” “we,” “us,” “our”).
Your privacy is very important to us. Please read this statement carefully. It is important that you make an informed decision when it comes to choosing whether to share any of your personal information with us.
Unique identifiers can be used for various purposes, including remembering your browsing preferences, your purchase history, directing advertising specifically to you, collecting information about your browsing history, as well as determining whether emails sent to you by us were received and/or opened.
We also use the information we collect from your use of our existing programs and services to help us develop new ones, and at times to send you personalized ads based on your particular interests. However, we do not use sensitive information such as race, sexual orientation, religion, or health to determine which ads we send you, and we do not collect genetic or biometric data (ex., fingerprints, retina patterns, voice waves).
Unique identifiers are sometimes stored in “cookies” (see below) to help websites display certain content in your browser and to remember, for example, your preferred language.
NOTE: You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. More about cookies below.
Data We Collect
- contact information such as email addresses and telephone numbers;
- business/company name
- job title;
- demographic information such as zip code, preferences and interests;
- date of birth;
- financial information such as credit / debit card numbers;
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
- a list of URLs starting with a referring site, your activity on our Site, and the site you exit to (automatically collected);
Why We Collect and Store Information from Your Computer
As indicated above, data regarding your computer hardware and software, including your IP address, browser, dates and times of access, domain names, and websites that referred you here, may be collected by the Site for purposes of improving the quality of the information and services provided; to understand our visitors’ preferences; to make improvements to our visitors’ overall experience of this website; market research and/or analysis, and to personalize this experience where doing so would improve the enjoyment of the Site.
With the data we collect from your computer hardware and software, we are able to learn about the number of visitors to our Site and the types of technology visitors use on our Site. However, we do not track or record information about individuals and their visits (unless they are willingly participating in one of our programs) and we do not share this data with anyone outside the Company unless necessary for law enforcement purposes (see “disclosure exceptions” below). In other words, while we may be tracking what your computer is doing, we are not tracking the various individuals that may be using a particular computer unless they have identified themselves as a participant in one of our programs.
Interacting with You
The contact information we collect from you, such as email, phone, text messaging, home/business address, is used to interact with you directly. We never want to abuse this privilege; however, it is our main method for contacting and communicating with our subscribers and clients. It’s a way for us to deliver information to you and also to notify you of upcoming programs we’re offering.
If you’re already a client, we use email to communicate with you directly as a method of providing information about how to use our programs.
You may choose to unsubscribe from all mailings by clicking the “unsubscribe” link at the bottom of all emails we send. You may also email us directly about your privacy preferences. (See our contact information below.)
Google Analytics and Facebook Pixels
Gathering Personal Data with Your Consent
Personal information that uniquely identifies you is only gathered with your explicit authorization and only in exchange for information, products, or services, whether free or paid. Be advised that if you choose not to provide this information you will not be able to receive information, products, or services offered by us to you as we will not have the means to deliver it to you.
You always have ultimate control over the information you receive from us. Note that some of your information may be shared with third party payment processors and credit card companies in order to process payment transactions and the delivery of our products and/or services to you.
We will never intentionally disclose any information regarding your personal identification to any third party without your consent. If you choose to provide us with such information, you agree to receive information, products, or services from this website.
If at any time you wish to opt-out, or unsubscribe, you may do so by clicking “unsubscribe” at the bottom of any email you receive from us, or by notifying the Company directly. See our contact information below. Rest assured that you always have the ability to manage your contact information.
NOTE: We may share information that does not include a unique identifier and would not reasonably be considered “personal data” in that it does not include information that would allow anyone to identify you as an individual. For example, advertisers or outside services may use non-personal data to enhance the experience of a visitors to their websites.
Third Party Analytics Service Providers
As indicated above, this Website may use third party analytics service providers such as Google Analytics, Google AdSense, and Facebook Pixels to evaluate and provide us and/or third parties with information about the use of the Website and viewing of content on the Site.
Data Collection Technologies We Use
We use various technologies to collect and store information, including cookies, (text files placed on your hard drive by our server to store information about the way you use our Site so that it can recall that information in order to personalize your next visit), pixel tags (technology used to track your website activity), web browser storage, databases, and server logs.
Data Obtained Indirectly
The Company may obtain data indirectly from third parties such as social networks and other public sources, including public databases.
As indicated above, we may also obtain information from third-party analytics services like Google Analytics and Facebook.
Retention and Storage of Your Personal Information
The Company retains your personal information only for as long as reasonably necessary to fulfill the purpose for which it was collected, as well as to comply with applicable laws. You may make a request to remove any and all data collected by us. See our contact information below.
We take appropriate technical and organizational measures to ensure a level of security appropriate to the level of risk.
This website will disclose your personal information, without notice, but only if:
- It is required to do so by law;
- As required by service of process;
- To defend our rights and property;
- To protect the personal safety of visitors to this website.
Data Protection Laws
Data protection laws differ from state to state (in the United States) and from country to country, with some having greater protections than others. We strive to maintain the highest level of privacy for anyone who shares information with us, regardless of where they reside.
The California Online Privacy Protection Act (CalOPPA) requires California companies to provide an opportunity for California residents to opt-out or unsubscribe from having personal information used by third parties (such as advertisers or affiliated companies) for direct marketing purposes.
This Company is a California based business and therefore does honor behavioral advertising opt-out or “do not track” mechanisms. This includes general web browser “Do Not Track” settings and signals.
If you are a California resident you may contact to exercise your disclosure choice options. See our contact information, below.
Children: Minimum Age Requirement
This website complies with the Children's Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the Internet.
This website is intended for persons eighteen (18) years of age or older. Per COPPA rules, anyone under the age of thirteen (13) must seek the permission of a parent or guardian before using this website.
However, no one under the age of eighteen (18) should visit this website – EVER.
Furthermore, this website will not knowingly contact or collect personal information from anyone under 18 and does not intend to solicit information of any kind from persons under the age of 18.
European Union Residents
Be advised that some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”), which includes all EU member states, plus Norway, Iceland and Liechtenstein. By using our site and submitting your information to us you are deemed to accept and agree to this. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. This includes but is not limited to the use of legally binding contract terms between us and any third parties with whom we engage and the use of the EU-approved Model Contractual Arrangements.
Correcting or Updating Your Information
You are invited to help us keep your personal data up to date by notifying us of any changes to your personal information. You may contact us to correct or update your personal information.
How to Contact the Company
Address: 4050 3rd Ave #310, San Diego, CA 92103
Phone Number: (619) 317-7057
Please be sure to put “ATTN Privacy Officer” in the subject line of your email or on the front of the envelope.
UPDATED: Friday, May 25, 2018