PRIVACY POLICY

Last updated May 24, 2018 to provide even more transparency and comply with the new European Union General Data ProtectionRegulation (GDPR), which gives individuals in the EU more control over how their data is used.

Your privacy is important to Pommel Co., LLC. d/b/a Hannah Keyes (“Pommel Co.,” “we,” “our,” or “us”) so we want you to know how we collect and use your personal information and your rights related thereto.

By visiting and using any our websites (including hannahkeyes.co, hhkys.co, pommel.co, pommelco.com, and any subdomains thereof), you agree and consent to the following Privacy Policy governing the collection and use of personally identifiable and other information by us.

Information we collect and how we use it

Pommel Co. may collect and use information from you when you voluntarily sign up for our e-mails or free gifts, register for a webinar or workshop, leave comments, order a service or product, fill out any type of form, access private membership pages, or otherwise contact us via an online form or e-mail. The information collected may include your name, e-mail, address, phone number, and billing information. You are not required, however, to provide any personally identifiable information to merely access or visit the website.

You may also voluntarily submit personal information to us through third-party sources such as our online scheduling system, shopping cart, webinar provider, survey or form providers, and social media.

Pommel Co. collects such information in order to send e-mails, schedule calls, fulfill orders, deliver services and products, host free events, complete customer transactions, oversee contests and promotions, improve website performance, and provide customer service.

If you subscribe to our email list(s) and later wish to unsubscribe, you may do so at any time. Each e-mail from our distribution list includes a link for unsubscribing from our e-mail communications.

We may also obtain information about you from third-party sources such as public databases, social media platforms, and third-party data providers. These sources may provide information such as age, gender, IP addresses, city, state and country location, and online behavioral data. We use this information, alone or in combination with other information we collect, to enhance our ability to provide you with relevant content, marketing, products, features, and services.

Cookies and tracking

Pommel Co. may also collect domain information and “cookies” (small files saved on your hard drive by your web browser) to analyze website and advertisement performance, deliver relevant advertisements, track user patterns, save information from your previous visits, and customize your experience.

Pommel Co. or its third-party vendors may collect nonpersonal information through the use of these technologies. Nonpersonal information might include the browser you use, the type of computer you use and technical information such as the operating systems and the Internet service providers utilized to connect. Our systems may also automatically gather information about the areas you visit and search terms you use and about the links you may select from within our websites to other areas of the Internet.

Data Retention

We maintain records up to 6 years unless you remain an active e-mail subscriber or customer in which case we reserve the right to continue to maintain your records in order to serve you.

Security

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable authorities of a suspected data security breach where we are legally required to do so.

How we share your information

Pommel Co. respects your privacy and will never sell, trade or transfer your personally identifiable information to third parties for marketing or advertising. Your information, however, may be shared with third party service providers working on behalf of Pommel Co. to serve you. Examples include companies and individuals engaged to maintain and update our websites, e-mail platforms, and process and reconcile financial transactions. Pommel Co. may also be required by law to release information in certain circumstances.

Pommel Co. may also release personal information to enforce our Website Terms and Conditions of Use, other Terms and Conditions, manage our business, protect users or the general public, or to otherwise comply with legal obligations.

If you give us your permission, we may also use personal identification information for internal or external marketing and promotional purposes.

Please note that any comments or information that you post on the website, including the membership site and social media pages, are not private and third parties may make use of your information. Pommel Co. is not responsible for any unauthorized uses by third parties in such context.

Miscellaneous

Any third party links to products or services are subject to separate privacy policies. Pommel Co. is not responsible for or liable for any content on or actions taken by such third-party websites.

This website and any products and services offered herein are targeted and intended for persons over the age of 13. Pommel Co. does not knowingly collect information from anyone under 13 years of age.

This Privacy Policy applies only to Pommel Co. online activity. It does not apply to information collected or used from other offline sources such as information collected at events or conferences.

EEA Rights

If you are located in the European Economic Area (EEA) and entitled to protection under the GDPR, we are considered a “controller” of the above mentioned personal information for the purposes of those laws. For EEA visitors, please be aware that our websites are operated in the United States and **any information you provide will be transferred there**. By using our websites or providing us your information, you consent to this transfer. You may learn more about your privacy rights under the GDPR at: [https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/](https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/) . If you would like to exercise any of those rights, please contact us at hannah@hannahkeyes.co.

Updates

Pommel Co. may change, modify or update this Privacy Policy at any time. If you have any questions or concerns about this Privacy Policy, contact us at hannah@hannahkeyes.co.