Privacy Policy

Simon Sinek Inc. and its affiliates, The Optimism Company, LLC, Optimism Productions LLC, Optimism Training, LLC, and Optimism Press LLC (collectively "SSI", "we", "our", or "us") provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive via our website (the "Site"), our mobile application (the "App"), and through the use of any services provided by us through the Site or App (the "Services"). This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. Your use of the Site, App and/or any of our Services following any such notice will signify and constitute your assent to and acceptance of such revised Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms used herein have the same meanings as in our Terms of Service.

1. Information We Collect

Our primary goals in collecting information are to provide and improve our Service, to administer your orders, to communicate with you, and to enable users of the Site and App to enjoy and easily navigate them.

When you wish to contact us, create an account on the Site or App, edit account details, purchase products or services via the Site or App, use some of our Services, or when you join our mailing lists, we will ask you for certain Personal Information. When we refer to your "Personal Information" in this Privacy Policy, we mean information that identifies, describes, relates to, references or is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. We may also collect other information generated when you use our Site, App, or Services that is not linked or otherwise associated with you, and such information is not subject to the terms of this Privacy Policy.

Depending on how you use our Site, App and/or our Services, we may directly collect the following types of Personal Information from you:

• your name;
• e-mail address;
• shipping address;
• billing address;
• credit card account number;
• IP address;
• telephone number; and
• online identifiers you use, such as your username, social media handles, and other similar types of identifiers.

2. Information from Social Networking Sites

Our Service may include interfaces that allow you to connect with social networking sites (each an "SNS"). If you connect to a SNS through the Site or App, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

3. Information Automatically Collected

When you visit our Site, some information is automatically collected. For example, when you visit our Site your computer's operating system, Internet Protocol (IP) address, access times, browser type and language, and the Site you visited before our Site are logged automatically ("Usage Information"). We also collect information about your usage and activity on our Site.

A. Cookies

We may automatically collect information using "cookies." Cookies are small data files stored on your hard drive by a Site. Among other things, cookies help us improve our Site and your experience. We use cookies to see which areas and features are popular and to count visits to our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other sites.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit allaboutcookies.org and, if you are in the UK or European Union (EU), youronlinechoices.com/uk.

B. Web Beacons

We may collect information using Web beacons. Web beacons are electronic images that may be used on our Site or in our emails. We use Web beacons to deliver cookies, count visits, understand usage and to tell if an email has been opened and acted upon.

C. Local Shared Objects

We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or to display content based upon what you view on our Site to personalize your visit. Third party partners provide certain features on our Site and Services and display advertising based upon your Web browsing activity using Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and way in which data is stored. Cookie management tools provided by your browser usually will not remove Flash cookies. To limit the websites that can store information in flash cookies on your device, you can use the Adobe Settings Manager available at: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

D. Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to better assist the Company in understanding how the Site is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Site, including your computer's IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on Site activity for SSI's use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the Site. The use of cookies by Google Analytics is covered by Google's Privacy Policy.

4. Information Collected from Other Third Parties

We may receive your Personal Information from third party business partners, such as social media sites, ad networks and analytics providers. We may also receive your Personal Information from others that refer you to our Sites and/or Services.

5. Use of Information

We use your Personal Information collected for the purposes described in this Policy. Specifically, we may use your Personal Information to:

• operate and improve our Site and Services;
• understand you and your preferences to enhance your experience;
• track, collate, and analyze your use of our Site and Services;
• process and deliver contest entries and rewards;
• respond to your comments and questions and provide customer service;
• provide and deliver products and Services you request;
• send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• facilitate your participation in surveys, promotional offers, contests or sweepstakes;
• communicate with you about new contests, promotions, rewards, upcoming events, and other news about products and Services offered by us and our selected partners; and
• link or combine it with other Personal Information we get from third parties, to help understand your needs and provide you with better service.

6. Sharing of Information

We do not share your Personal Information with third parties except in the following circumstances:

Affiliates and Subsidiaries. We may share your Personal Information with our affiliates and subsidiaries with the understanding that they will treat such information consistent with this Privacy Policy.

Third Party Service Providers. We may share your Personal Information with our third party vendors, consultants and other service providers who work for us and need access to your information to provide you with products, services, or information that you request. For example, we use Klaviyo to facilitate our email communications, Intercom to provide customer support, and Zoom Video Communications, Inc. to conduct online classes.

Other Third Parties. We may share your Personal Information with appropriate third parties if we believe it is necessary, in our reasonable discretion, to (i) comply with laws or to respond to lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (ii) protect the rights and property of us, our agents, customers, members, and others including to enforce our agreements, policies and terms of use; or (iii) in an emergency to protect the personal safety of the Company, its customers, or any person.

Corporate Restructuring. We may share your Personal Information in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another entity.

With Your Consent. We may share your Personal Information with third parties where you have provided consent to such sharing.

We may also share aggregated anonymous or de-identified information. When we use the term "anonymous data", we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create anonymous data from the Personal Information we receive about you and other individuals whose Personal Information we collect. Anonymous data might include analytics information and information collected by us using cookies. We make Personal Information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.

7. Payment Card Information

We do not collect, store, or process any payment card information. Instead, we rely on Stripe to facilitate any payment card transactions. For more information about Stripe's privacy practices, please see Stripe's Privacy Policy.

8. Email Opt-Out and Disabling Cookies

A. Email Opt-Out

You may opt out of receiving promotional emails from us by following the instructions in those emails or sending a message with your request and the subject line "EMAIL OPT OUT REQUEST" to [email protected]. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

B. Disabling Cookies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site and Services.

9. Third Party Sites and Links

Our Site, App, and Services may contain links to third party sites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their sites, features or policies. Please read their privacy policies before you submit any data to them.

10. Children's Information

Our Site and Services are not directed to children under the age of 13. If you are under 13, you may not access, attempt to access, or use our Site, App, or Services. We do not knowingly collect or allow the collection of Personal Information via the Site, App, or Services from persons under the age of 13, pursuant to applicable law and regulations. If we learn that we have collected the Personal Information of someone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information to us, you may contact us at [email protected] and ask us to remove your child's Personal Information from our systems.

11. Information Security

We take reasonable organizational, technical and administrative steps to help protect Personal Information against loss, misuse, unauthorized access or disclosure. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure.

12. App Permissions and Mobile Device Features

When you use the App, you may choose to enable certain mobile device features. If you do, we may collect and use information associated with those features as described below. You can control and revoke permissions at any time through your device settings.

Push Notifications. If you opt in to receive push notifications, we may collect a device push token and information about notification delivery and interaction (e.g., whether a notification was opened) to send you updates and service-related messages.

Camera / Photos / Media Library (if enabled). If you allow the App to access your camera or photo/media library, we may access photos or media you choose to upload or use within the App (for example, for profile images or user-generated content). We do not access your photo library unless you choose to grant permission and select content to share with us through the App.

Microphone (if enabled). If you allow microphone access, we may collect audio only when you actively use a feature that requires it (for example, voice notes).

Location (if enabled). If the App offers location-based features and you grant permission, we may collect your approximate or precise location (as permitted by your device settings) to provide those features.

Contacts / Calendar (if enabled). If the App offers features that use your contacts or calendar and you grant permission, we will access only the information needed to provide that feature (for example, inviting contacts or syncing reminders).

13. Your California Privacy Rights

If you are a California resident, you have the right to request information from us regarding the manner in which the Company shares certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above.

Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

• the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
• the names and addresses of the third parties that received the information; and
• if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized format that is not specific to you. The designated email address for these requests can be found at: [email protected].

Additionally, if you are a California resident and are under the age of 18 and you have posted content or information to our Site or Services, you can request that we remove content or information that you have posted to our Site or Services. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by other individual).

Also, please note that we have not yet developed a response to browser "Do Not Track" signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to "Do Not Track" signals in light of industry developments or legal changes.

14. Non-U.S. Privacy Rights

If you are located outside the United States, including in the European Union, European Economic Area, United Kingdom, Switzerland, or other jurisdictions with data protection laws, you may have certain rights with respect to your Personal Information to the extent provided under applicable law.

Legal Bases for Processing

Where required by law, we process Personal Information on one or more of the following legal bases:

• Performance of a contract (for example, to provide our Services);
• Your consent, where obtained, which may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal;
• Compliance with legal obligations; and
• Our legitimate interests, except where such interests are overridden by your fundamental rights and freedoms, including improving and securing our Services, developing new features, and preventing misuse.

Your Rights

Subject to applicable law, you may have the right to:

• Access your Personal Information;
• Request correction or update of inaccurate or incomplete Personal Information;
• Request deletion of your Personal Information;
• Restrict or object to certain processing activities;
• Receive a copy of your Personal Information in a portable format; and
• Withdraw consent at any time, where processing is based on consent.

You may also have the right not to be subject to decisions based solely on automated processing, including profiling, where such decisions produce legal or similarly significant effects, except as permitted by law.

Exercising Your Rights

You may submit requests to exercise your rights by contacting us at [email protected]. We may need to verify your identity and may limit or deny requests as permitted by applicable law, including where requests are excessive or manifestly unfounded. We will respond within the timeframes required by applicable law.

You also have the right to lodge a complaint with your local data protection authority or supervisory authority, where applicable.

International Data Transfers

Your Personal Information may be transferred to and processed in countries outside your jurisdiction, including the United States. Where required by law, we rely on recognized legal transfer mechanisms, such as:

• Adequacy decisions adopted by relevant authorities;
• Standard contractual clauses or equivalent contractual safeguards; and
• Other lawful transfer mechanisms permitted under applicable data protection laws.

Where applicable, we also rely on recognized data privacy frameworks approved by relevant authorities, including the EU–U.S. Data Privacy Framework, the UK Extension to the EU–U.S. Data Privacy Framework, and the Swiss–U.S. Data Privacy Framework, for transfers of Personal Information to the United States. We may update the transfer mechanisms we rely upon as required by applicable law.

The Company previously certified to the U.S. Department of Commerce that it adhered to the applicable Data Privacy Framework Principles with respect to personal data received from the European Union, United Kingdom, and Switzerland. The Company's certification is currently inactive and we are in the process of pursuing active status.

To the extent the Company continues to retain personal data that was received under the Data Privacy Framework during the period of certification, the Company will continue to apply the applicable Data Privacy Framework Principles to such personal data unless and until it is deleted or otherwise processed in accordance with applicable law.

Additional information about the Data Privacy Framework program is available at: https://www.dataprivacyframework.gov/

15. Complaints and Dispute Resolution

We take privacy concerns seriously and are committed to working with individuals to resolve complaints regarding our collection, use, or transfer of Personal Information.

If you have questions or complaints about our data handling practices, including with respect to international data transfers, please contact us at: [email protected].

We will investigate and respond to complaints in accordance with applicable data protection laws and within the timeframes required by law.

Data Privacy Framework–Related Complaints (Where Applicable)

Where the Company relies on an applicable Data Privacy Framework for transfers of Personal Information to the United States, we commit to resolving complaints related to such transfers in compliance with the relevant framework principles.

If a complaint relating to such transfers cannot be resolved directly with us, we may, where required, refer unresolved complaints to an independent dispute resolution provider, such as JAMS (Judicial Arbitration and Mediation Services, Inc.), located in the United States, at no cost to the individual. Information about JAMS and the complaint process is available at: https://www.jamsadr.com/dpf

In limited circumstances and as provided under the applicable Data Privacy Framework principles, an individual may have the right to invoke binding arbitration to resolve a complaint that has not been resolved by other means.

16. Regulatory Oversight

Where applicable, the Company is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to its compliance with applicable privacy and data protection obligations.

17. Changes to This Policy

We may update this Privacy Policy from time to time. When changes are made, we will revise the "Effective Date" indicated above. If we make material changes, we will provide notice on our website prior to such changes taking effect. Your continued use of the Site and/or our Services following the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated terms, you should discontinue use of the Site and our Services.

18. Contacting Us

If you have any questions about this Privacy Policy, please contact us at [email protected].