Let’s talk about your privacy

This Privacy Policy describes the policies and procedures of Guillermo Copello (“I”, “me”, or “my”) on the collection, use, and disclosure of your information on guillermocopello.com (the “Site”) and the services, features, content, or applications I offer (together with the Site, the “Services”).

I receive information about you from various sources, including: (i) if you register for the Site and the Services, through your user account on the Services (your “Account”); (ii) your use of the Services generally; and (iii) from various third-party websites and other services. All defined terms not defined herein shall have the meaning ascribed to them in the Terms of Service, available at guillermocopello.com/terms.

What does our policy cover?

This Privacy Policy covers my processing of Personal Data that I gather when you are accessing and using the Services. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage, and disclosure.

This Privacy Policy also covers my treatment of any Personal Data that my business partners share with me or I share with my business partners. This Privacy Policy does not apply to the practices of third parties, and their sites, services, or applications that I do not own or control, or to individuals that I do not employ or manage (“Third Parties”). While I attempt to provide access only to those Third Parties that share my respect for your privacy, I cannot take responsibility for the content, actions, or privacy policies of those Third Parties. I encourage you to carefully review the privacy policies of any Third Parties you access.

If you are a resident of the European Union, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under European Union Regulation (EU) No. 2016/679 of 27 April 2016, also known as the General Data Protection Regulation or GDPR (the “GDPR”) with respect to your Personal Data, as outlined below. I may be the controller of your Personal Data processed in connection with the Services for purposes of the GDPR. If you have any questions about this Privacy Policy or whether any of the following applies to you, please contact me at copelloguillermo60@gmail.com.

Note that I may also process Personal Data of my users’ own customers, end users, or employees in connection with my provision of services to customers, in which case I am the processor of Personal Data for purposes of the GDPR. If I am the processor of your Personal Data (i.e., not the controller) for purposes of the GDPR, please contact the controller of your Personal Data (i.e., the user or individual providing the course, product, or other offering in connection with which you provided your Personal Data) in the first instance to address your rights with respect to such data.

What Personal Data does Guillermo Copello Collect From You?

I collect Personal Data about you when you provide such information directly to me, when third parties such as my business partners or service providers provide me with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of my Services.

Information I collect directly from you: I receive Personal Data directly from you when you provide me with such Personal Data, including without limitation the following:

First and last name Email address Billing zip code and/or country of residence

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Site and Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device when you use that device to visit our Site. We sometimes combine information collected through Cookies that is not Personal Data with Personal Data that we have about you, for example, to tell us who you are or whether you have an account with us. We may also supplement the information we collect from you with information received from third parties. Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Site or using our Services, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Site or Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Services, how often you return, how your use of the Services may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Services. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because we collect browsing and persistent identifier data, the Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave our properties. Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Site or Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies. We use the following types of Cookies: Essential Cookies. Essential Cookies that are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site or Services. Disabling these Cookies may make certain features and services unavailable.

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable my servers to recognize your web browser and tell me how and when you visit and use my Site and Services, to analyze trends, learn about my user base and operate and improve my Services. Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device when you use that device to visit my Site. I sometimes combine information collected through Cookies that is not Personal Data with Personal Data that I have about you, for example, to tell me who you are or whether you have an account with me. I may also supplement the information I collect from you with information received from third parties.

Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting my Site or using my Services, whereas “persistent Cookies” are stored on your device for a period of time after you leave my Site or Services. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. I use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit my Services, how often you return, how your use of the Services may vary over time. I also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, I may collect information about your online activity after you leave my Services. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because I collect browsing and persistent identifier data, the Services do not support Do Not Track requests at this time, which means that I may collect information about your online activity both while you are using the Services and after you leave my properties.

Some Cookies are placed by a third party on your device and may provide information to me and third parties about your browsing habits (such as your visits to my Site or Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third-party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that I or others believe are relevant to you. I do not control third-party Cookies.

I use the following types of Cookies:

Essential Cookies. Essential Cookies that are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of my Site or Services. Disabling these Cookies may make certain features and services unavailable.

Functionality Cookies. Functional Cookies are used to record your choices and settings regarding my Services, maintain your preferences over time and recognize you when you return to my Services. These Cookies help me to personalize my content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Performance/Analytical Cookies. Performance/Analytical Cookies allow me to understand how visitors use my Site and Services such as by collecting information about the number of visitors to the Site, what pages visitors view on my Site and how long visitors are viewing pages on the Site. Performance/Analytical Cookies also help me measure the performance of my advertising campaigns in order to help me improve my campaigns and the Services’ content for those who engage with my advertising. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google’s use of cookies by visiting the Google advertising opt-out page or the Google Analytics Opt-out Browser Add-on.

Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that I can provide advertising that I believe is relevant to you. For more information about this, please see the section below titled “Additional information about interest-based advertisements.”

You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find our more information about Cookies, including information about how to manage and delete Cookies, please visit ico.org.uk/for-the-public/online/cookies/ or allaboutcookies.org.

Additional information about interest-based advertisements:

I may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to me by you, or derived from the usage patterns of particular users on the Services and/or services of Third Parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties. To accomplish this, I or my service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for me and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about Interest-Based Ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt out pages, which are located at networkadvertising.org/choices or aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website youronlinechoices.eu.

I do not share your Personal Data with advertisers without your consent. However, if you click on or otherwise interact with an advertisement there is a possibility that the advertiser may place a Cookie in your browser and note that it meets the criteria they selected.

How Do I Use Your Personal Data?

I process Personal Data to operate, improve, understand and personalize my Services. For example, I use Personal Data to:

Communicate with you about the Services Protect against or deter fraudulent, illegal or harmful actions Allow you to create and/or manage your digital storefront, your sales pages, and your online courses Allow you to create, manage, and/or subscribe to membership software Allow you to create, manage, and/or sell digital files Allow you to create, manage, and/or sell digital downloads and online courses Contact you about Service announcements, updates or offers Personalize website content and communications based on your preferences Provide support and assistance for the Services Discover others who might be interested in the Services To identify trends and other statistical information that may be useful to my business Comply with my legal or contractual obligations Resolve disputes Enforce my Terms of Service (including, for clarity, the Privacy Policy and, where applicable, the EU Data Processing Addendum)

I will only process your Personal Data if I have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and my “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: I process the following categories of Personal Data as a matter of “contractual necessity,” meaning that I need to process the data to perform under my Terms of Service with you, which enables me to provide you with the Services. When I process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

First and last name Email address User Content (which can include Personal Data if you include Personal Data in such content) IP address Billing zip code and/or country of residence

Legitimate Interest: I process the following categories of Personal Data when I believe it furthers the legitimate interest of me or third parties.

First and last name Email address IP address Billing zip code and/or country of residence

Examples of these legitimate interests include:

Protection from fraud or security threats

Operation and improvement of my business, products and services

Marketing of my products and services, directly to you and to others

Provision of customer support

Compliance with legal obligations

Completion of corporate transactions

Consent: In some cases, I process Personal Data based on the consent you expressly grant to me at the time I collect such data. When I process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time I may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do I Share Your Data?

I share Personal Data with vendors, third-party service providers and agents who work on my behalf and provide me with services related to the purposes described in this Privacy Policy or my Terms of Service. These parties include:

Payment processors Fraud prevention service providers Analytics service providers Hosting service providers Marketing service providers Email providers Staff augmentation and contract personnel

I also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services) Social media services (if you interact with them through your use of the Services) Third-party business partners who you access through the Services, including vendors Other parties authorized by you

I also share Personal Data when I believe it is necessary to:

Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. Protect me, my business or my users, for example to enforce my Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Maintain the security of my products and services.

As part of the Services, you will receive from me email and other communications. You acknowledge and agree that by availing yourself of the Services, you allow me to send you email and other communication that I determine in my sole discretion relate to your use of the Services.

I also share information with third parties when you give me consent to do so. Furthermore, if I choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if I, or substantially all of my assets, were acquired, or if I go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and I would share Personal Data with the party that is acquiring my assets. You acknowledge that such transfers may occur, and that any acquirer of me or my assets may continue to use your Personal Data as set forth in this policy.

How Long Do I Retain Your Personal Data?

I retain Personal Data about you for as long as you have an open account with me or as otherwise necessary to provide you Services. In some cases I retain Personal Data for longer, if doing so is necessary to comply with my legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, I retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do I Use?

I seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. You need to prevent unauthorized access to your Account and Personal Data by selecting and protecting your password appropriately and limiting access to your device and browser by signing off after you have finished accessing your Account.

I seek to ensure that user account information is kept private. However, I cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Do I Store the Personal Data of Children?

As noted in the Terms of Service accessible at guillermocopello.com/terms, I do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to me. If I learn that I have collected Personal Data from a child under age 16, I will delete that information as quickly as possible. If you believe that a child under 16 may have provided me Personal Data, please contact me at copelloguillermo60@gmail.com.

What Do Users in the European Union Need to Know?

Rights Regarding Your Personal Data

By law, users in the European Union, United Kingdom, Lichtenstein, Norway, or Iceland have certain rights with respect to their Personal Data, including those set forth below. For more information about these rights, or to submit a request, please visit your Account settings at guillermocopello.com/account/billing or email me at copelloguillermo60@gmail.com. Please note that in some circumstances, I may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, I will still respond to notify you of such a decision. In some cases, I may also need you to provide me with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access: You can request more information about the Personal Data I hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing me at copelloguillermo60@gmail.com.

Rectification: If you believe that any Personal Data I am holding about you is incorrect or incomplete, you can request that I correct or supplement such data by emailing me at copelloguillermo60@gmail.com. You may also be able to correct some of this information directly by making updates to your account.

Erasure: You can request that I erase some or all of your Personal Data from my systems.

Withdrawal of Consent: If I am processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of my Services.

Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that I transmit the data to another controller where technically feasible.

Objection: You can contact me to let me know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

Restriction of Processing: You can ask me to restrict further processing of your Personal Data.

Right to File Complaint: You have the right to lodge a complaint about my practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Guillermo Copello and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Guillermo Copello in the U.S. and will be hosted on U.S. servers, and you authorize Guillermo Copello to transfer, store and process your information to and in the U.S., and possibly other countries. If you live in the European Union, Iceland, Liechtenstein, or Norway, you hereby consent to the transfer of your data in accordance with Exhibit B to the EU Data Processing Addendum, which can be located at guillermocopello.com/dpa. Please contact me at copelloguillermo60@gmail.com with any questions or concerns.

What If You Have Questions Regarding Your Personal Data?

If you have any questions about this Privacy Policy or my data practices generally, please contact me using the following information:

Guillermo Copello copelloguillermo60@gmail.com 425 NE 22nd St Miami, FL, 33137

Changes to this Privacy Policy:

I may amend this Privacy Policy from time to time. Use of information I collect now is subject to the Privacy Policy in effect at the time such information is used. If I make changes in the way I use Personal Data, I will notify you by posting an announcement on my Site or Services or sending you an email. Users are bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.