Privacy Policy

Updated on November  18, 2023

WEBMARK ADVISORS LLC  provider, is a company headquartered at 1309 Coffeen Avenue STE 1200, Sheridan,
Wyoming, 82801, US.

The Company is responsible for processing the data of its customers and, more generally, of Internet users (hereinafter referred to as “you“) browsing the websites it operates in the course of its business, such as https://Webmarkadvisors.com and their sub-sites, including the online training platform and/or private group on a social network offered to its customers (hereinafter referred to interchangeably as the “Site”).

We are committed to ensuring that the collection and processing of personal data is carried out lawfully, fairly and transparently, in accordance with the General Data Protection Regulation (“GDPR”).

Failure to provide mandatory information may result in the data collection request (e.g. online registration or order, request for information, etc.) not being processed or being delayed.

If you have any queries or complaints, please do not hesitate to contact us by e-mail at Contact@webmarkadvisors.com.

1. DEFINITIONS – PREAMBLE

For a proper understanding of this Privacy Policy, the following terms should be specified: 

– Personal data” means any information relating to an identified or identifiable natural person (the “data subject”), in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to that person’s identity.

– Processing” means any operation involving personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

– A “controller” is the person who, alone or jointly with others, determines the purposes and means of processing, and a “processor” is the person who processes personal data on behalf of the controller.

– A “recipient” is the natural or legal person, public authority, department or any other organization that receives personal data, whether or not it is a third party.

Warning. Please be careful about what you make public on the Internet. With regard to personal data, including data relating to your private life or sensitive data (political and philosophical opinions, trade union membership, health information, sexual orientation, religious beliefs, etc.) made public at your initiative or deduced from your contributions, comments and opinions of any kind on social networks (Facebook, Youtube, etc.), please note that processing of personal data made public by the person concerned is not subject to the general prohibition on processing sensitive data.

If a word is capitalized, the Customer may refer to the general terms and conditions of sale applicable on the Site.

1. MANAGING THE CUSTOMER-PROSPECT DATABASE

Through the Site, you provide us with the following categories of information by filling out the information form(s) and communicating with us:

– Identity data (title, surname; first name), contact data (e-mail address; postal address (address, zip code, city, country); telephone number)

– Your user account login and password information

In the event of an order, we will also process information relating to the contractual and commercial relationship that you may enter into, and in particular to the correct correspondence of information relating to the order of a Training session and a Coaching session reserved for Training session members. As the order is subject to a fee, we will also process payment and transactional information (transaction date, amount, payment method, order number).

We also collect information when you complete a satisfaction form or subscribe to a free product or service (name, e-mail). Subscribing to a free service implies acceptance of receiving commercial information, and the User may unsubscribe at any time thereafter.

Lastly, we collect data on account connections and the use of tools made available to people in the virtual space dedicated to them (IP address, connection time, connection duration, account settings, tool management, videos viewed, progress indicators).

Accuracy of information provided: You must not provide any false personal information and must not create an account for another person without that person’s authorization. The contact details you send us must always be accurate and up to date.

Personal identifiers – All account holders who access a virtual space (training, viewing, etc.) have access rights that are strictly personal, confidential and non-transferable. All account holders must take the necessary security measures to preserve the integrity of their access rights (login, password) to prevent third parties from connecting to their account. The holder of access rights shall be liable for any fraudulent or abusive use of his/her access codes, where this is the result of his/her own negligence. In any event, the holder of access rights must inform us without delay of the loss or theft of his or her access codes.

III. PROVISION OF A VIRTUAL SPACE FOR ACCESS TO SERVICES

Training content is delivered on a dematerialized platform accessible via a URL link provided to the customer when the order is placed. Coaching is delivered via private groups on social networks, notably Facebook.

Email Notifications – The “Please notify me of updates to my products” and “Please notify me when a reply to one of my messages or comments is created” boxes that may be provided to Customers on a virtual space to receive email notifications (product updates, replies to one of my messages or comments) may be unchecked at any time.

1. SOCIAL NETWORKS AND THIRD-PARTY SITES

Groups, accounts and pages. All coaching can be delivered via a private group created on Facebook, where content is shared and customers can interact. We may also contact you or answer your questions via social networks, if you have contacted us in the first instance via this channel. Finally, we have various public pages and accounts to which you can subscribe.

Regarding any information you may provide to the social network Facebook (liking a video, viewing a video, messages sent to coaches), Instagram (commenting, liking, sharing…) and any other social network, we inform you that we are not responsible for the processing of personal data carried out by this third-party site, and you are invited to consult the personal data protection policies for more information.

Outside the Training course :

Public information: The information about you that you have sent us may be enriched for commercial, prospecting, communication, solicitation or marketing purposes, by means of other sources of information such as social networks (so-called “public” information or information to which we may have access as page administrator).

Links to third-party sites. The Site may provide links to sites, applications and services other than its own, which may be operated by third-party companies. Clicking on these links may allow third parties to collect or share data about you. In this case, we are not responsible for the processing of personal data by these third-party sites, whose personal data protection policies the user is invited to consult for further information.

Link to the Site. Conversely, if one of the third-party sites points to our Site (URL link), this does not mean that the privacy policy of this third-party site is applicable to our activity, nor that we guarantee compliance by this third party with its obligations in terms of personal data protection.

1. COOKIES

Collection of technical data for advertising, commercial and statistical purposes. Your device’s technical data is automatically collected and recorded by the Site for advertising, commercial and statistical purposes. This information helps us to personalize and continually improve your experience on our Site. We do not collect or store any nominative data (surname, first name, address, etc.) that may be attached to technical data. This data may be sold to third parties by the suppliers of the cookies used to collect it.

Cookies/pixels provided by third parties such as Facebook and Google enable retargeting, for more information see :

– https://www.facebook.com/business/learn/facebook-ads-pixel

– https://policies.google.com/technologies/cookies?hl=fr

Cookie retention period. In accordance with European recommendations, cookies are kept for a maximum of 13 months after they are first stored on the User’s terminal, as is the period of validity of the User’s consent to the use of these cookies. The lifetime of cookies is not extended with each visit. The User’s consent must therefore be renewed at the end of this period.

Purpose of cookies. Cookies may be used for statistical purposes, in particular to optimize services rendered to the User, based on the processing of information concerning access frequency, page personalization, operations carried out and information consulted. You are informed that the cookie supplier may place cookies on your terminal. The cookie records information relating to navigation on the service (the pages you have consulted, the date and time of consultation, etc.) which we can read during your subsequent visits. Certain functions on the site, such as video players or interactive content, may use services provided by third parties and may deposit cookies enabling them to identify your consultation of the content.

The User’s right to object to cookies. If you do not wish cookies to be used on your terminal, most browsers allow you to disable cookies via the settings options:

– Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=fr

– Safari: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

– Firefox: https://support.mozilla.org/fr/kb/protection-renforcee-contre-pistage-firefox-ordinateur

– Internet explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

1. EXERCISE OF RIGHTS

You have a right of access to your data, rectification or deletion, interrogation, limitation of the processing of your data, portability, and deletion (more info here), within the limits set by regulations and in particular the RGPD.

You also have the right to object at any time, for reasons relating to your particular situation, to the processing of personal data whose legal basis is our legitimate interest, as well as the right to object to commercial prospecting by clicking on the unsubscribe link in the newsletter.

Requests to exercise your rights should be sent electronically to the following address: Contact@webmarkadvisors.com If you are not satisfied with our response, you may lodge a complaint with the US Data Protection Authority.

For all intents and purposes, it is hereby specified that upon exercising the right to erasure, to object to processing, or to withdraw consent, the proper functioning of the site and/or training services (including the e.learning platform) may be disrupted or even interrupted. For example, if these rights are exercised at the time of ordering services, the said order may not be carried out.

VII. RETENTION PERIOD FOR PERSONAL DATA

Data used to manage commercial prospecting is kept for a maximum of three years from the last contact from the prospect or the end of the contract with the customer. If you have not logged on to the Site or been active (for example, by clicking on a link) for a period of three years, you may receive an e-mail inviting you to log on as soon as possible, failing which your data will be deleted from our databases.

Means for the effective deletion of data are put in place as soon as the retention or archiving period necessary for the fulfillment of the determined or imposed purposes is reached, in particular after deletion of your account with our company.

In accordance with our legal obligations, certain documents relating to our internal operations and containing personal information (purchase orders, contracts, invoices, etc.) will be archived. Similarly, we may archive documents until the expiry of the limitation/forclosure periods applicable to legal actions, in order to defend our interests before the courts in the event of subsequent litigation.

In any event, personal data will not be kept beyond the time required to fulfill the obligations defined when the contract was concluded, or as required by current legislation. Beyond this period, the data may be anonymized and stored exclusively for statistical purposes.

VIII. MAILING

We do not sell any personal data files. The information you give us is for internal use by authorized persons. It is strictly confidential and may not be divulged to third parties, except with your express consent or if you have decided to make it public.

Our external service providers may, in the context of the processing operations described above, receive personal data in order to carry out processing operations. This is the case for tools supplied under the Namecheap name (site hosting).

As such, we verify that (i) any processor presents sufficient and appropriate contractual guarantees to respect your rights, so that the processing meets the requirements of the GDPR and (ii) to comply with the provisions of the GDPR applicable to data transfers.

On the basis of our legal obligations, your personal data may be disclosed in application of a law, regulation or by virtue of a decision by a competent regulatory or judicial authority.

Transfers outside the EU. We undertake to comply with the applicable regulations relating to the transfer of data to countries outside the European Union, in particular as follows:

– We will transfer the data of visitors, prospects and customers to countries recognized as offering an adequate level of protection. In the case of transfers to the United States, to organizations that have signed up to the Privacy Shield;

– When the country of destination does not offer an adequate level of protection, we use transfer tools that comply with regulations, such as the European Commission’s standard contractual clause.

1. IT SECURITY

We undertake to implement all appropriate technical and organizational measures using physical and logistical security measures in order to guarantee a level of security appropriate to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of your personal data.

Secure payment

All transactions carried out on our Site are secure. Credit card payments are handled by our partner STRIPE, a trusted payment service provider. We use SSL encryption to protect your personal data and the means of payment used. Thanks to this process, we are never in direct possession of your bank details.

The address of the payment page begins with “https” and is accompanied by a closed padlock or key in the bottom right-hand corner of your browser. This allows you to check that you are in a secure payment zone when you are asked for your credit card number. Stripe automatically checks that this connection is secure before sending your banking and transaction data.

General – Data breach

We undertake to implement all appropriate technical and organizational measures using physical and logistical security measures in order to guarantee a level of security appropriate to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of your personal data.

In the event that we become aware of unlawful access to your personal data stored on our servers or those of our service providers, or of unauthorized access resulting in the risks identified above, we undertake to :

– Notify you of the incident as soon as possible if required by law;

– Examine the causes of the incident;

– Take all reasonable steps to mitigate any adverse effects and damages that may result from the said incident

Under no circumstances may the commitments defined in the above point be assimilated to any recognition of fault or responsibility for the occurrence of the incident in question.

If you observe any security breach or incident that may affect the integrity of your personal data or that of others, we would be grateful if you would inform us immediately by e-mail at Contact@webmarkadvisors.com.

1. APPLICABLE LAW AND LANGUAGE

This privacy policy is written in French. In the event of translation into one or more languages, the French text shall prevail in the event of litigation. The temporary or permanent non-application of one or more clauses of the present policy shall not constitute a waiver of the other clauses of the present policy, which shall continue to have full effect.

We reserve the right to modify this Privacy Policy. Data subjects will be notified when this is provided for by the RGPD or any other regulation. The update date is indicated in the header and we invite you to consult it regularlyelise