(last updated March 12, 2020)

1. Introduction

This Privacy Policy applies to all the products, services, websites and apps offered by Masterfully, LLC (“Masterfully”), except where otherwise noted. We refer to those products, services, websites and apps collectively as the “services” in this policy. 

References to “personal information” or just “information” in this Privacy Policy will refer to information about you personally that we collect or for which we act as custodian.

2. Information we collect about you

Contact Information (for example name or email address). You might provide us with your contact information, whether through use of our services, a form on our website, an interaction with our sales or customer support team, or a response to a survey.

Usage information. We collect usage information about you whenever you interact with our websites and services. This includes which webpages you visit, what you click on, when you perform those actions.

Device and browser data. We collect information from the device and application you use to access our services. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, and browser type. If you are on a mobile device, we also collect the UUID for that device.

Information from page tags. We use first party and third party cookies and tracking services that employ cookies and page tags (also known as web beacons) to collect data about visitors to our websites. This data includes usage and user statistics. Emails sent by Masterfully or by users through our services also include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We provide more information on cookies below.

Log Data. Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.

Referral information. If you arrive at Masterfully’s website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.

Information from third parties and integration partners. We collect your personal information from third parties where, for example, you give permission to those third parties to share your information with us or where you have made that information publicly available online.

Registration information. You need a Masterfully account before you can use Masterfully services. When you register for an account, we may collect your first and last name, email address, telephone number, the name of your company, your industry, your organizational role, the number of employees/learners at your company, your country and your state. 

Billing information. If you make a payment to Masterfully, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment. If you provide a billing address, we will regard that as the location of the account holder and the sales tax, if applicable, to be applied to your purchase.

Account settings. You can set various preferences and personal details on pages like your account settings page. For example, your default language, time zone and communication preferences (e.g. opting in or out of receiving marketing communications from Masterfully).

Profile information. When you sign up for our services you are asked to provide us with information about yourself and to give us more detailed insights into who you are.

3. How we use the information we collect

We process personal data about you either with your consent or in order to:

  • Fulfill our contractual responsibility to deliver the services to you; and
  • Pursue Masterfully’s legitimate interests of improving service experience and developing new products and service features.

In each of the instances where we describe how we use your data in this Privacy Policy, we have identified which of these grounds for processing we are relying upon.

Cookies and Similar Technology. You have consented to us using certain types of tracking and third party cookies on our websites. In particular, we or third party data and advertising platforms that we work with may use or combine multiple technologies, such as cookies, page tags, mobile identifiers and IP addresses to infer users’ common identities across different services and multiple devices such as tablets, browsers, and mobile phones. We may do so, for instance, to tailor ads to users, to enable us to determine the success of our advertising campaigns and to improve upon them. These third party data and advertising platforms may sometimes use data that we provide to them in order to improve their technologies and their ability to match common devices to users. 

More details: The above data and techniques are used for personalized marketing, analytics, and related purposes. To learn more about interest-based advertising and how to opt-out of it, please see Section 6 regarding cookies, below. We use this data to personalize online marketing campaigns to be relevant to you and your interests in our services. By clearing your cookies in your browser settings you will no longer see personalized messages in this way, but you may continue to see ads that are not based on information you provided to Masterfully.

Personal Information. We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this Privacy Policy. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.

Contact Information. We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (either where you have agreed to this at the point of providing your information or where you operate in a business which may be interested in our services and for as long as you do not opt-out).

More details: We use your email address to send you marketing (newsletters), unless you indicate a preference to opt-out and for general updates on your account. You can opt out of marketing communications at any time by clicking on the “unsubscribe” link in an email message or by contacting us.

How you use our services. We use information about how you use our services to improve our services for you and all users.

More details: We collect information about the types of services you use and purchase and your account transactional behavior to build a profile about you so as to help direct you and your organization to other relevant features and services we offer and help you in using our services, for example by making recommendations for you to optimize use of our services.

Device and browser data. We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based on your IP address.

More details: We collect this to help us improve your service experience through a specific device/browser by optimizing how the website looks in a particular browser, how your screen brightness affects your experience and to ensure the service operates optimally and as it should on different devices and browsers.

Log data. We may use log data for many different business purposes, which include:

  • To monitor abuse and troubleshoot.
  • To create new services, features, content or make recommendations.
  • To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services.
  • To fix bugs and troubleshoot product functionality.

More details: Your IP address is used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).

Referral information. We use referral information to track the success of our integrations and referral processes.

Third parties and integrations. We may collect and use information from third parties and integration partners, where applicable to one of our services, to personalize our services for you and ensure you can use our services in conjunction with other services.

Profiling. We combine information about you from third party sources with information we hold about you to create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve your service experience.

To manage our services, we will also internally use your information and data in order to:

  • Provide and improve our services
  • Offer outstanding customer care
  • Identify and troubleshoot issues
  • Determine opinions through surveys
  • Communicate with customers
  • Send important information related to our services
  • Offer updates to our applications and software
  • Save study progress and stats
  • Improve and enforce our security measures
  • Curb fraud and illegal behavior
  • Enforce terms, agreements and policies
  • Comply with law and law enforcement

Legal uses. To respond to legal requests or prevent fraud, we may need to use and disclose information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

We collect and use the following on the basis that we have to use this information in order to fulfill our contract with you:

Your Account Information. We need to use your account information to run your account, provide you with services, bill you for our services, provide you with customer support, and contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You cannot opt out of these communications since they are required to provide our services to you.

Your Profile. We process other aspects of your account information (like the personal information you provide about your job, your job title, and your marketing preferences) as well as information obtained from public sources, for legitimate interests like providing you with a personalized experience and relevant and useful marketing information as well as to make other product, feature and service recommendations to you and your organization to optimize use of the services we offer.

You can object to us using your information as described above, but in some cases, our ability to fully and properly provide our services to you may be impacted if you do not want us to collect or use the above data.

4. Information you share

Many of our services let you share information with others. Remember that when you share information publicly, it can be indexable by search engines. Our services provide you with different options on sharing and deleting your content but we cannot delete content from search engines so you need to be careful about information you make public.

5. Information we share

We do not share your information or data with third parties outside Masterfully except in the following limited circumstances:

  • We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.
  • On your instructions, we share your information or data if you choose to use an integration in conjunction with Masterfully services, to the extent necessary to facilitate that use. 

We also may have to share information or data in order to:

  • meet any applicable law, regulation, legal process or enforceable governmental request.
  • enforce applicable policies, including investigation of potential violations.
  • detect, prevent, or otherwise address fraud, security or technical issues.
  • protect against harm to the rights, property or safety of our users, the public or to Masterfully and/or as required or permitted by law.
  • facilitate a sale, merger or change in control of all or any part of our company or business or in preparation for any of these events.

We may use third parties to assist us in service delivery for you, and they may process your data as part of that service. A list of these third parties is available upon request. Please keep in mind that your service may only be impacted by a subset of these sub-processors. 

Additionally, we use Google Analytics, LiveHelpNow and New Relic. The use of personal information by these services is governed by their respective privacy policies:

6. Cookies

We use cookies and similar technologies on our website. We may also use certain cookies that you agree to when you use our sites and, in the case of some cookies, for legitimate interests of delivering and optimizing our services (where the cookie delivers essential functionality). Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies primarily to establish and maintain a login session for our Advisor Plus service, but cookies and similar technologies may also be used for other reasons, including:

  • To gather metrics about your experience. However, this information is collated and kept at an aggregated and anonymized level only.
  • To make our site easier to use. If you use the “Remember me” feature when you sign into your account, we store your username in a cookie to make it quicker for you to sign in whenever you return to Masterfully.
  • For security reasons. We use cookies to authenticate your identity and confirm whether you are currently logged into Masterfully or determine if an incident impacts you.
  • To provide you with personalized content. We store user preferences, device and browser information, your profile information which includes the level of usage of service and the web-pages on our site which you visit, so we can identify you across devices and personalize the content you see.
  • To improve our services. We use cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services (it helps us focus on the parts of the service you seem most interested in) and optimize the content we display to you (which may include marketing content).

Google Analytics. In addition to the above, we have implemented on our websites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.

You can choose to remove or disable cookies via your browser settings.

7. Security

Masterfully uses commercially reasonable ethical, physical, managerial, and technical safeguards to preserve the integrity and security of your personal information consistent with industry standards. For example, we use encryption, passwords, and physical security measures to help protect your personal information against unauthorized access and disclosure. The security of your personal information is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is ever 100% secure. While we strive to use commercially reasonable means to protect your personal information, we cannot ensure or warrant the absolute security of any information you transmit to Masterfully, and you do so at your own risk. When Masterfully receives a transmission of personally identifying information from you, Masterfully makes commercially reasonable efforts to ensure the security of such information on our systems. However, please note that this is not a guarantee that such information will not be accessed, disclosed, altered, or destroyed by breach of any of our ethical, physical, technical, or managerial safeguards. While we strive to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online.

In the event that personal information is compromised as a result of a breach of security, Masterfully will notify those persons whose personal information has been compromised as soon as practicable, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.

8. Safety of Minors

Our services are not intended for and may not be used by minors. “Minors” are individuals under the age of 13 (or under a higher age if permitted by the laws of their residence). Masterfully does not knowingly collect personal data from Minors or allow them to register. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.

9. Changes to our Privacy Policy

We can make changes to this Privacy Policy from time to time. We will identify the changes we have made on this page. In circumstances where a change will materially change the way in which we collect or use your personal information or data, we will post notice on our website and may also send a notice of this change to account holders.

10. Personalized marketing

You can opt-out of direct marketing in your account and we provide opt-out options in all direct marketing emails. Finally, if you do not wish to see personalized marketing content on the web related to our services, you can clear the cookies in your browser settings. 

11. Your rights

This section describes the rights you may have generally as a customer of any Masterfully service.

You may wish to exercise a right to obtain information about yourself or to correct, update or delete that information. Some of these rights may be subject to some exceptions or limitations under local law. Please note that your rights and choices vary depending upon your location. We will take reasonable steps to verify your identity and we will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request).

You are entitled to a copy of all personal data which we hold in relation to you. You may also be entitled to restrict how we use your data or object to some aspect of our treatment of your data. You can access some of your data in your own account when you log in. If you want to exercise your rights, please contact us at:

Masterfully LLC
265 South Street, Suite B
San Luis Obispo, CA 93401
(805) 545-0012
[email protected]

Alternatively, if your request is for the right to be forgotten as it relates only to our use of cookies, you can achieve this by clearing the cookies in your browser settings. 

For rights and choices specific to California consumers, please see below. Please note we will take reasonable steps to verify your identity and the authenticity of your request. Once verified, we will maintain your request in the event our practices change.

12. Your California Privacy Rights

Supplemental Privacy Notice to California Residents: We do not give, share, or sell any personal information to a third party unless required by law, but to comply with California’s “Shine the Light” law (codified at California Civil Code section 1798.83), provide you with the following, supplemental notice:

If you are a California resident, you are entitled to request and obtain from us once per calendar year information regarding “personal information” about you (as that term is defined under California Civil Code section 1798.83) that we shared, if any, to a third party for the third party’s direct marketing purposes. The information will include (1) a list of the categories described in California Civil Code section 1798.83(e)(6) that were disclosed in during the preceding calendar year, if at all, and (2) the names and addresses of all of any third parties with whom we shared any such personal information about you during the preceding calendar year, and if the nature of such third parties’ business cannot reasonably be determined from the third parties’ name, a description of the nature of the third parties’ business or examples of products and services that the third party marketed.

To make such a request, please email us at [email protected], and include “Request for California Privacy Information” in the subject line. We will provide the requested information to you at your email address.

13. Exercising your rights

Except as explicitly provided herein, please use the following Contact Information for Privacy Inquiries:

Masterfully LLC
265 South Street, Suite B
San Luis Obispo, CA 93401
(805) 545-0012
[email protected]

Note that our contact form is the best way to make a rights request with us.