Privacy Policy

Updated Date: April 1, 2024

INTRODUCTION

Welcome! You have arrived at a website owned and operated by Renegade (“We” or “Company“) and we are committed to doing our part to protect the privacy of all individuals with whom we interact. We provide the website accessible at Mitowimgmt.com (the “Website“) for your convenience and informational purposes. We will not conduct business with you solely through our Website.

This Privacy Policy is designed to answer your questions about:

the information we collect when you access or use the Website,
how we collect such information;
how we use that information;
with whom we may share that information;
where we store that information;
the rights you have with regard to the information we collect; and
how you can exercise your rights regarding the information.
SCOPE

This Notice applies when you:

use or access a website or landing page owned or operated by Renegade or that links to this Notice, including, but not limited to renegadebreakfree.com, mitowimgmt.com, acupuncturesuccessstories.com and their subdomains or portals (the “Sites”);
use a product or attend a workshop from Renegade; or
otherwise provide Personal Information or interact with us online or in-person.

For the purpose of this Notice, “Personal Information” means any personal information relating to an identified or identifiable individual that is protected by applicable privacy laws. We refer to all of the above as “Services.” By using the Services, you agree to our Terms of Service.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it.

If you have any questions about this Privacy Notice, please contact us at concierge@mitowimgmt.com

CONTROLLER

For information we collect through the Website and the various services, information, classes, and methods of interacting with Company provided through the Website (the “Services”), Company determines how that data is Processed, and Company is the Controller. You may contact Company with any questions about how we Process your personal information using the information at Contact Us.

APPLICABILITY OF THIS POLICY

This Privacy Policy applies to all information we collect on or as a result of your accessing or using the Website; using any Services we provide through the Website; or any communication you have with us via the Website or related electronic communications, such as emails or texts.

This Privacy Policy does not apply to information we collect offline or through any other means, including websites or mobile applications that do not incorporate this Privacy Policy or third parties that may link to our be accessible from or through the Website. This Privacy Policy does not apply to information collected about our employees who may utilize the Website to access certain tools we make accessible to employees. Employees should reference the Company Employee Privacy Policy for information on how their information is handled.

BINDING AGREEMENT

Please read this Privacy Policy carefully. By accessing or using the Website or the Services, you agree to us Processing your information as described in this Privacy Policy. “Processing” your information includes collecting, using, storing, disclosing, and otherwise manipulating your information. This Privacy Policy may change from time to time, and you should review UPDATES TO THIS PRIVACY POLICY to understand when and how it might change. Your continued use of the Website or the Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

If you do not agree to us Processing your information as stated in this Privacy Policy, do not use the Website or the Services and do not submit any Personal Information to us.

INFORMATION WE COLLECT

All information we Process about individuals is either personal information or non-identifying information. We may use the personal information and the non-identifying information to create aggregated information.

“Personal Information” is any Information that relates to, describes, references, is reasonably capable of being associated with, is linked to, or could reasonably be linked to, a particular individual, household or device, such as an individual’s name, postal address, email address, telephone number, or other online identifier. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

“Non-Identifying Information” is any Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual, household, or device.

“Aggregated Information” is information about groups or categories of data subjects or individuals, which does not identify and cannot reasonably be used to identify an individual.

We do not collect “Sensitive Personal Information,” which includes: race or ethnicity; religion; citizenship; genetic data; biometric data used to identify a person; precise geolocation; personal information of children; union membership; SSN; DL or passport number; financial account with password or security code; contents of mail, email or texts (unless a business is the intended email recipient); medical and health information that does not otherwise constitute Personal Health Information (or “PHI”); and in the EU, criminal records.

HOW WE COLLECT INFORMATION

We collect information:

Directly from you when you provide it to us.
Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies
From third parties, for example, our business partners.

Information You Provide

As you interact with our Sites or Services such as when you attend a workshop, take a quiz, assessment or survey, fill out a form, or make a purchase on the Sites, we may collect the following Personal Information via webforms on our Sites, and through emails and other communications with you:

Contact and account information. We may collect information such as your first and last name, email address, home or business address, telephone numbers, mobile numbers and password;
Quiz, assessment and survey information. When you take one of our quizzes, assessments or surveys, we may collect information such as your business/industry, company name, title, company revenue and other information provided.
Financial information. We may collect information such as your credit card or debit card number, bank account information and your payment, service and purchase history;
Social media information. We may collect information such as social media handles, content and other data shared with us through third-party features that you use on our Sites or Services (such as tools, payment services, widgets and plug-ins offered by social media services like Facebook, Instagram, Twitter and Pinterest) or posted on social media pages (such as our social media page or other pages accessible to us);
Other information. We may collect other information that could reasonably be used to identify you personally or identify your household or device.

Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Sites or Services.

In addition to those types of information, you also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Automatically Using Various Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your activity on our Website, including details about how you access our Website, which pages of the Website you access, how long you access specific pages, the information you download; and other communication data and the resources that you access and use on the Website.
Whether or not we have previous contact or relationships with you for business development purposes (i.e. a sales lead or a customer entered or tracked through our CRM);
Information about your computer, including your operating system, device ID, browsing history, search history,
Mobile device information, including your operating system type and version, screen resolution, device language setting, device type, model, and manufacturer, mobile carrier, operating system and other device attributes;
The different devices you have used to access the Website;
Information about your internet connection or the equipment you use to access the internet, including your IP address;
The location of your device (city and state);
Information about whether you’ve engaged with Company’s brand on social media platforms such as Facebook, LinkedIn, and Twitter;
Derived information reflecting your employer’s name;
Information about the categories of websites you have browsed outside of our Website.
When you call our customer service team, we record the calls for quality and training purposes;

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please see COOKIE POLICY for more detail on how we use these technologies. Please see YOUR INFORMATION – YOUR CHOICES for more information on your rights with respect to the information we Process, and EXERCISING YOUR RIGHTS for information on how to exercise those rights.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

We do not collect personal information automatically, but we may tie information we collect automatically to personal information that we collect from other sources or that you provide to us. We do this to offer special discounts and to improve our marketing, analytics, and site functionality.

Analytics tools are a specific type of automatic data collection tools. For a complete list and more information on the analytic tools we use, please see COOKIE POLICY.

Information We Collect from Third Parties. We supplement or update the information you provide to us and the information that we collect automatically with information provided to us by third parties. For example, we may use a third party service to verify and/or update your postal addresses when we are shipping something to you. Examples of other information we might receive from third parties are:

Personal Information such as your name, personal and professional email addresses, and personal and professional phone numbers;
Profile information, comments, and similar information provided to or on social networks and other forums that connect to us;
Interests, demographic data and purchasing behavior;
Information collected from you offline or through other channels, such as information you provide when attending an in-person event or function or information you provide to us over the phone. ,

Information We Do Not Collect

We do not collect biometric information or sensory data on the Website. We do not collect non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).

Information Collected Historically (within the last twelve (12) months)

During this time, we have collected the following types of information about users of our Website:

Category	Examples	Collected
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers	YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. (Some personal information included in this category may overlap with other categories.)	YES
Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	NO
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	NO
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	NO
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement	YES
Geolocation data	Physical location or movements	YES
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	NO
Professional or employment-related information	Current or past job history or performance evaluations	NO
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	NO

Collection of Non-Identifiable Information

We also collect data in a form that does not, on its own, allow us to identify a specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. Examples of non-personal information that we collect and how we may use it are language, zip code, area code, referrer URL, and the time zone where a Company website or service is used or accessed so that we can better understand user behavior and improve our services. We also may collect information regarding user activities on our Website and from our other services and aggregate that information to help us provide more useful information to our users and to understand which parts of our Website and Services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.

Your Responsibilities With Regard to Information We Collect

If you provide any personal information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their personal information in accordance with this Policy.

You are responsible for ensuring the accuracy of personal information you provide to us. Inaccurate information may affect your ability to use the Services, including the information you receive when using the Services and our ability to contact you. While you are not required to provide the personal information that we request, if you chose not to do so, we may not be able to provide you with our Services or respond to questions you may have.

HOW WE USE INFORMATION

Consistent with applicable law and the choices and controls that you select EXERCISING YOUR RIGHTS, we may use your information for the purposes described in this Privacy Policy, including, but not limited to:

Fulfilling any purpose for which you present the information to us;
Presenting our Website and its contents to you;
Providing you with the experiences, products, and services you request, view, engage with, or purchase;
Allowing you participate in interactive features on our Website;
Providing you with updates about Company’s latest happenings and upcoming events;
Communicating with you about your account or transactions with us, including, providing you with notices about your account, including expiration and renewal notices;
Providing you with information about Company, our Services and our business activities;
To comply with any applicable COVID-19 tracing efforts;
For customer service and customer support purposes;
Sending you information or requesting feedback about features on our Website or about changes to our policies;
Sending you offers and promotions for our products and services or third-party products and services;
Personalizing content and experiences presented to you;
Providing you with targeted advertising based on your activity on our Website or on third-party sites and applications;
Providing you with information on our own or third party products or services based on your activity on our Website or on third-party sites and applications;
Operating, understanding, optimizing, developing, or improving our Website, products, services and operations, including by using guest survey research and analytics tools;
Displaying advertisements from third parties where it appears that your information matches the target criteria specified by the third party (for this purpose, your information is not shared with or provided to the third party);
Detecting, investigating and preventing activities that may violate our policies, pose safety issues, or be fraudulent or illegal;
Testing, research, analysis, and product development, including development and improvement of our Website, and products, and services;
Notifying you of product recalls or safety issues;
Fulfilling our obligations or enforcing our rights arising from any contracts entered into between you and us, including for billing and collection;
To prevent transactional fraud;
Notifying you about changes to our Website, or any products or services we offer or provide;
Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets being transferred;
To speed up your searches;
To provide, personalize, measure, and improve your experience with our Website and Services, and to deliver content and Services;
Estimate our audience size and usage patterns;
To help maintain and improve the safety, security, and integrity of our Website and Services;
Recognize you when you return to our Website so that we can return you to where you were on the Website;
To support our general business operations;
In any other way we may describe when you provide the information.
For any other purpose with your consent;
For any other lawful purpose that is our legitimate interest and not overridden by your data privacy rights;

To learn more about how we use your information for personalization and tracking, please see COOKIE POLICY.

Our Legal Basis for Processing Your Data:
We have determined that our legal basis for the different types of data process are as follows:

Our legal basis for:	Is:
Processing data enabling us to get in touch with you	Our legitimate interests, namely, the proper administration of our business or the performance of a contract between you and us
Processing your personal data for the purposes of operating our Website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment related documentation, and credit control	Our legitimate interests, namely the proper administration of our Website, services and business, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
Processing your personal information for the purposes of publishing your information on our Website, and elsewhere through our Services in accordance with your express instructions	Your consent; or our legitimate interests, namely the publication of content in the ordinary course of our operations, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
Processing your contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling	Our legitimate interests, namely, communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business
Processing usage data and/or transaction data for the purposes of researching and analyzing the use of our website and services, as well as researching and analyzing other interactions with our business	Consent; or Our legitimate interests, namely, monitoring, supporting, improving and securing our website, services and business generally;
Processing your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally	Our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this notice
Processing your personal data for the purposes of security and the prevention of fraud and other criminal activity	Our legitimate interests, namely the protection of our website, services and business, and the protection of others
Processing your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice	Our legitimate interests, namely the proper protection of our business against risks
Processing your personal data where necessary for [the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure	Our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others
Processing your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person	Our legitimate interests, namely the proper protection of our business against risks

Company strives to collect only the personal information that we need for our business. We do not sell or share your personal information in exchange for money.

Some privacy laws define the sale of data to include sharing personal information for a business purposes. In that case, we may sell or share your personal information with a third party for a business purpose, but when we do so, we enter into contracts requiring those third parties to keep your personal information confidential and to use it only for the purpose it was provided to them.

Personal Information: We may share your information in the following situations:

To fulfill the purpose for which you provided it;
To our affiliates (such as other companies that own us, that we own, or that share common ownership with us);
When you allow us to share your personal information with another company, by electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services;
When you direct us to share your personal information with another company to fulfill your request;
When you direct us to share your personal information with third-party sites or platforms, such as social networking sites.
When we cooperate with other businesses to offer co-branded products or services to you; however, we will do so only if permitted by applicable law, and, in these cases, the other business will be prohibited from using your personal information for purposes other than those related to the co-branded products or services;
When companies perform services on our behalf, like package delivery, marketing and advertising, and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law;
When requested by law enforcement agencies, regulators, and courts in response to a court order, subpoena, regulatory requirement or similar legal process, to report any activities we reasonably believe to be unlawful or as otherwise required by law;
To combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of a legal proceeding affecting Company;
When we share your personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.
When it is necessary to respond to a public health emergency, or in an emergency, to protect the safety of your health and property;
For any other purpose we disclosed when collecting the information;
With your consent.

Aggregated or Non-Identifying Information: We may disclose aggregated information or non-identifying information, for any reason without restriction.

Information Shared Historically (within the last twelve (12) months)

We may share your personal information with third parties for business purposes (and it may constitute a sale under certain state laws). We do not sell the personal information about individuals we know are under age 16. For more information on the personal information of children, please see PRIVACY RIGHTS OF CHILDREN.

During this time, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information Category	Category of Third-Party Recipients
Identifiers	Affiliates, Service Providers, Business Partners, Social Media
California Customer Records personal information categories	Affiliates, Service Providers, Business Partners, Social Media
Protected classification characteristics under California or federal law	N/A
Commercial information	Affiliates, Service Providers, Business Partners, Social Media
Biometric information	N/A
Internet or other similar network activity	Affiliates, Service Providers, Business Partners, Social Media
Geolocation data	Affiliates, Service Providers, Business Partners, Social Media
Sensory data	N/A
Professional or employment-related information	Affiliates, Service Providers, Business Partners, Social Media
Non-public education information	N/A
Inferences drawn from other personal information	N/A
Log-In, Account, or Financial Card Number, in combination with required Access Code	N/A

We sell (if considered a sale under applicable state privacy laws), share, and/or disclose this personal information for the same purposes set out in HOW WE USE INFORMATION.

Sensitive Personal Information

We do not collect, store, sell (if considered a sale under applicable state privacy laws), share, and/or disclose sensitive personal information.

YOUR INFORMATION / YOUR CHOICES

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:

The Right to Know/Right To Access

You have the right to know what personal information we have collected about you. Upon receipt of your request, and confirmation of your identity, we will disclose to you:

the categories and specific pieces of personal information that we have collected about you in the past 12 months,
the sources from which we have collected that information,
Our business or commercial purpose for collecting such information;
The categories and specific pieces of personal information that we have disclosed to third parties for a business purpose during the past twelve months;
The categories and specific pieces of personal information that we have sold to third parties during the past twelve months;
The third parties to whom we have disclosed or sold such personal information.

In most cases, you may request this information up to two times each year.

The Right to Data Portability

You have the right to request a copy of the personal information we have about you. We will provide it in a format that we select, that you can reasonably transfer to a third-party.

The Right to Correct/Right to Rectification

You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions. To make requests, please reach out to us at concierge@mitowimgmt.com

The Right to Delete/Right to Erasure

You have the right to request that we delete any of your personal information, subject to applicable legal exceptions. If you submit a request for your personal information to be deleted, we will review your request and attempt to confirm your identity. If we confirm your identity, we will review the request to see if an exception allowing us to retain the information applies. If no exception applies, we will delete your personal information and direct our service providers to do the same.

We may deny your deletion request, for example, if retaining the personal information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with any international, national, federal, state, or local laws, rules or regulations, applicable to us or to your personal information.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of Promotional Offers

If you do not wish to have your email address or other contact information used by Company to promote our products or services, you can opt-out of non-essential email or text communication by contacting us as provided in Contact Us. If we have sent you a promotional email or text, you may send us a return email or text asking to be omitted from future email distributions.

Your election not to receive promotional and marketing correspondence from Company will not (a) preclude us from corresponding with you, by email, text or otherwise regarding your existing or past relationship with us, nor (b) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your personal information while maintaining and improving the Website.

Right to Opt Out of Targeted Advertising and Profiling

We share information about your use of our Sites and Services, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page here.

You can opt out of targeted advertising by visiting the following:

Right to Opt Out of Sale or Sharing of Personal Information

You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by applicable law). There may be situations where we cannot fulfill your requests if you opt-out of such sharing. If that is the case, we will make it clear at the time of collection that such sharing is required to fulfill your request for products or services.

You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so.

To opt-out of the sale or sharing of your personal information, you or your authorized representative should:

enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.
Submit a request to us by emailing concierge@mitowimgmt.com

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing concierge@mitowimgmt.com

You do not need to create an account with us to exercise your opt-out rights. We will use personal information provided in an opt-out request only to review and comply with the request.

EXERCISING YOUR RIGHTS

To exercise any of your rights, submit a request by:

Renegade Acupuncturist Media LLC

Attn: Concierge

30 N. Gould Street

Suite 22333

Sheridan, WY 82801

843-763-8901

concierge@mitowimgmt.com

When submitting a request, you must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such individual.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

VERIFICATION OF REQUESTS

Only you, or someone legally authorized to act on your behalf, may make a request regarding your personal information. A parent or guardian with legal custody may make a request on behalf of a minor child. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity.

We cannot, and will not, respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm the personal information relates to you.

While you are not required to submit the request through your account with us, we do consider request through your password protected account to be verified, without further requirements, as long as the request is for information associated with that account.

We will not use personal information provided in the request for any purpose other than to verify the requestor’s identity or authority to make the request.

Verifying an Authorized Agent

In certain circumstances, you are permitted to use an authorized agent, as that term is defined by applicable U.S. state privacy law (“Authorized Agent”) to submit requests on your behalf where you provide sufficient evidence that the requestor is an authorized agent with written permission to act on your behalf and you successfully verify your own identity with us. An Authorized Agent can make a request on the subject consumer’s behalf by:

• For requests to know and delete: (1) providing a valid power of attorney under the laws of the subject individual’s state of residence; or (2) providing sufficient evidence to show that the subject consumer has (i) provided the Authorized Agent signed permission to act on their behalf, (ii) verified their own identity directly with us, and (iii) directly confirmed with us that they have provided the Authorized Agent permission to submit the request on their behalf; and

• For requests to opt-out: submitting a signed permission demonstrating that the Authorized Agent has been authorized by the subject consumer to act on their behalf.

RESPONDING TO YOUR REQUEST

We will endeavor to confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email concierge@mitowimgmt.com to ensure your request was received.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have a password protected account with us, we will deliver our written response to that account. If you do not have a password protected account with us, we will deliver our written response by mail or electronically, to the address we have on file for you (not the address you specify in your request) at your option.

The information in our response will cover only the 12-month period preceding our receipt of your request. If we cannot comply with your request or any portion of your request, our response will explain the reasons we cannot comply. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

APPEAL PROCESS

If we refuse to take action upon your request to exercise any of your data privacy rights, you may appeal our decision within a reasonable period after you receive notice of our decision. To initiate an appeal, please contact us using the information in the Contact Us section and inform us that you would like to appeal our decision. Within forty-five (45) days after we receive your appeal, we will inform you of any action taken or not taken in response to your appeal, and we will provide you with a written explanation of the reasons in support of our response.

If your appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general to submit a complaint, should you wish to do so.

NON-DISCRIMINATION FOR EXERCISING YOUR RIGHTS

We will not discriminate against you for exercising any of your data protection rights, and specifically we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer certain financial incentives permitted by applicable Privacy Laws that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our products/services may not be able to take account of your interests and preferences. If collection of personal information is mandatory for successful provision of products/services, we will make that clear at the point of collection so that you can make an informed decision whether to participate.

NOTICE OF FINANCIAL INCENTIVES

From the time to time, we may run sweepstakes, contests, or other offers and promotions (collectively, “Programs”) that may be deemed “financial incentives” in relation to our collection of personal information under applicable data privacy laws. A business may offer financial incentives for the collection, sale or deletion of personal information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. We may run sweepstakes or contests from time to time. Please refer to the terms and conditions of each Program for additional information about the Program, including how eligible consumers can opt-in or opt-out of the Program at any time. In order to enter a Program, you may be required to provide us or a service provider acting on our behalf with certain personal information, such as identifiers including your name and contact information (“Rewards Data”). If you submit your entry in accordance with the applicable Program’s rules, you may be entered into the Program and will get a chance to win a prize or receive another benefit from us. The value of Rewards Data is related to the value of your information and the costs associated with offering the Program.

USER CONTENT

If you delete your User Content from the Website, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Content, is governed by our Terms of Use.

CHILDREN’S PRIVACY POLICY AND PRACTICES

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website, or through any of its features, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at concierge@mitowimgmt.com

DATA SECURITY, RETENTION POLICIES AND PRACTICES

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

GLOBAL DATA TRANSFER, STORAGE AND PROCESSING PRACTICES

The information you provide due to your use of the Website may be transferred or accessed by entities outside of the U.S. Where applicable, we use Standard Contractual Clauses approved by the European Commission or other comparable approved transfer mechanisms.

UPDATES TO THIS PRIVACY POLICY

From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. Any changes to this Privacy Policy will be posted to this page, with a notice that the Privacy Policy has been updated. The date the Privacy Policy was last revised is identified at the top of the page. Where required by applicable law, we will obtain your consent.

CONTACT US

If you have a comment or question about this privacy policy, please contact us at:

Renegade Acupuncturist Media LLC

Attn: Concierge

30 N. Gould Street

Suite 22333

Sheridan, WY 82801

843-763-8901

concierge@mitowimgmt.com

DEFINITIONS

AGGREGATE INFORMATION – Information about groups or categories of data subjects or individuals, which does not identify and cannot reasonably be used to identify an individual.

NON-IDENTIFYING INFORMATION – Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.

APPLICATION / APP – A program or service operated by us (or on our behalf) that may be displayed on various online, mobile, or other platforms and environments, including those operated by third parties, which permits us to interact directly with you.

CHILDREN – Individuals who we have identified are not of legal age to consent to the collection and processing of their personal information, and in the United States, includes all individuals under 13 years of age.

DATA CONTROLLER – The Company that is responsible for the personal information collected and used within the scope of this Privacy Policy from our Website.

DATA PROCESSOR – A person or entity that processes personal information on behalf of a data controller (or data controllers) and is permitted to perform data processing only as directed by the data controller(s).

IP ADDRESS – An IP address is associated with the access point through which you enter the Internet, and is typically controlled by your Internet Service Provider (ISP), your company, or your university. We may use IP addresses to collect information regarding the frequency with which you visit various parts of our Website, and we may combine IP addresses with personal information.

PARENTS –a parent or legal guardian.

PERSONAL INFORMATION – Information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address, and telephone number. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

PUBLIC FORUMS – Our Website may offer message boards, conversation pages, blogs, chat rooms, social community environments, profile pages, and other forums that do not have a restricted audience. If you provide personal information when you use any of these features, that personal information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party.

JURISDICTION SPECIFIC RIGHTS

UNITED STATES

California

California residents have the following rights:

Right to Know: You have the right to confirm whether we are processing your personal data.

Right to Access: You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.

Right to Delete: You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

Right to Opt Out of Sale or Sharing of Personal Information: You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by applicable law).

Right to Appeal: You have the right to appeal, within a reasonable time, our refusal to honor your exercise of these rights.

For information on how to exercise these rights, See: Exercising Your Rights.

California’s Mandatory Disclosures

See Information We Collect, Sharing and Selling Your Information and How We Use Your Information for our mandatory disclosures.

Shine the Light Act

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by the Company to third parties for the third parties’ direct marketing purposes. We take great pride in the relationship of trust we have built with our clients over many years and we are dedicated to treating your personal information with care and respect. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share guests’ personal information with third parties for those parties’ direct marketing use, unless you elect that we do so.

See Contact Us for information on how to contact us regarding questions about our privacy policies.

Colorado

Colorado residents have the following rights:

Right to Know: You have the right to confirm whether we are processing your personal data.

Right to Access: You have the right to access your personal data.

Right to Delete: You have the right to request that we delete personal information you provided or that was collected about you, subject to applicable legal exceptions.

Right to Correct: You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.

Right to Opt Out of Sale or Sharing of Personal Information: You have the right to “opt out” of targeted advertising (as defined under Colorado law). You have the right to opt-out of the sale of your data (as defined under Colorado law).

Right to Portability: You have the right to obtain a copy of the personal data that you provided to us.

Right to Appeal: You have the right to appeal, within a reasonable time, our refusal to honor your exercise of these rights.

For information on how to exercise these rights, See: Exercising Your Rights.

Connecticut

Connecticut residents have the following rights:

Right to Know: You have the right to confirm whether we are processing your personal data.

Right to Access: You have the right to access your personal data.

Right to Delete: You have the right to request that we delete personal information you provided or that was collected about you, subject to applicable legal exceptions.

Right to Correct: You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.

Right to Opt Out of Sale or Sharing of Personal Information: You have the right to “opt out” of targeted advertising (as defined under Connecticut law). You have the right to opt-out of the sale of your data (as defined under Connecticut law).

Right to Portability: You have the right to obtain a copy of the personal data that you provided to us.

Right to Appeal: You have the right to appeal, within a reasonable time, our refusal to honor your exercise of these rights.

For information on how to exercise these rights, See: Exercising Your Rights.

Iowa

Effective January 1, 2025, Iowa residents have the following rights:

Right to Know: You have the right to confirm whether we are processing your personal data.

Right to Access: You have the right to access your personal data.

Right to Delete: You have the right to request that we delete personal information you provided or that was collected about you, subject to applicable legal exceptions.

Right to Opt Out of the Sale of Personal Information: You have the right to opt-out of the sale of your data (as defined under Iowa law).

Right to Portability: You have the right to obtain a copy of the personal data that you provided to us.

Right to Appeal: You have the right to appeal, within a reasonable time, our refusal to honor your exercise of these rights.

For information on how to exercise these rights, See: Exercising Your Rights.

Nevada

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may do so as provided for in EXERCISING YOUR RIGHTS. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Utah

Effective December 31, 2023, Utah residents have the following rights:

Right to Know: You have the right to confirm whether we are processing your personal data.

Right to Access: You have the right to access your personal data.

Right to Delete: You have the right to request that we delete personal information you provided or that was collected about you, subject to applicable legal exceptions.

Right to Opt Out of Sale or Sharing of Personal Information: You have the right to “opt out” of targeted advertising (as defined under Utah law). You have the right to opt-out of the sale of your data (as defined under Utah law).

Right to Portability: You have the right to obtain a copy of the personal data that you provided to us.

Right to Appeal: You have the right to appeal, within a reasonable time, our refusal to honor your exercise of these rights.

For information on how to exercise these rights, See: Exercising Your Rights.

Virginia

Virginia residents have the following rights:

Right to Know: You have the right to confirm whether we are processing your personal data.

Right to Access: You have the right to access your personal data.

Right to Delete: You have the right to request that we delete personal information you provided or that was collected about you, subject to applicable legal exceptions.

Right to Correct: You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.

Right to Opt Out of Sale or Sharing of Personal Information: You have the right to “opt out” of targeted advertising (as defined under Virginia law). You have the right to opt-out of the sale of your data (as defined under Virginia law).

Right to Portability: You have the right to obtain a copy of the personal data that you provided to us.

Right to Appeal: You have the right to appeal, within a reasonable time, our refusal to honor your exercise of these rights.

Virginia’s Mandatory Disclosures

See Information We Collect, Sharing And Selling Your Information and How We Use Your Information for our mandatory disclosures.

There are various other U.S. states that have passed data privacy laws, but as of the date of this Privacy Policy, those laws are not in effect.

European Economic Area (GDPR – EEA)

For information on the data we collect, see INFORMATION WE COLLECT.
For information on how we use your personal information, see HOW WE USE INFORMATION.
When you access or use our Website, your personal data is controlled by E. A. Company & Company. We are a Controller as defined in GDPR.
You have a number of rights with regard to our collection, storage, use and sharing of your data, including:
- Right to Know: You have the right to confirm whether we are processing your personal data.
- Right to Access: You have the right to access your personal data.
- Right to Delete: You have the right to request that we delete personal information you provided or that was collected about you, subject to applicable legal exceptions.
  - For EU and UK residents, we may deny your request for deletion for if the information is necessary to:
    - Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
    - Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
    - Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
    - Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent;
    - Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
    - Comply with a legal obligation; or
    - Make other internal, lawful, and legitimate uses of that information that are compatible with the context in which you provided it and that are not overridden by your data privacy rights.
- Right to Correct: You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.
- Right to Opt Out of Sale or Sharing of Personal Information: You have the right to “opt out” of targeted advertising (as defined under Virginia law). You have the right to opt-out of the sale of your data (as defined under Virginia law).
- Right to Portability: You have the right to obtain a copy of the personal data that you provided to us.
- Right to Appeal: You have the right to appeal, within a reasonable time, our refusal to honor your exercise of these rights.
- Right to Revoke Your Consent: You have the right to withdraw your consent to the processing of your personal information without detriment at any time where we are relying on consent as the lawful basis for the processing of your personal information.
- Right to Change Your Marketing Preferences (Opt-In/Opt-Out): Right to Opt-Out/Right to Opt-In
- Right to Limit Processing of Your Data: You have the right to restrict processing of your personal information where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing.

See YOUR INFORMATION/YOUR CHOICES. For information on how to exercise your choices, see Exercising Your Rights.

You have a right to lodge a complaint with your local Data Protection Supervisory Authority or with the UK Information Commissioner’s Office: https://ico.org.uk/for-the-public

United Kingdom (GDPR UK)

The rights under the GDPR UK are the same as those under the GDPR EEA. See European Economic Area (GDPR – EEA).

Use of Cookies

We use cookies and other tracking technologies to personalize your experience, analyze user trends, and improve the Services. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Sites, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information.

You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Sites. For example, we may not be able to recognize your computer or device, and you may need to log in every time you visit.

We may use “cookies” (a small text file sent by your computer each time you visit our site) or similar technologies to record log data. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options.

We may use the following types of cookies:

Strictly necessary cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Functionality cookies. These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly. Performance cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Targeting cookies. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media cookies. These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

We might also use pixel tags, which are small graphic files that allow us and third parties to monitor the use of the Sites and provide us with information based on your interaction with the Sites. These tags may collect the IP address of the device from which you loaded the page and the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements.

Other data technologies may be used that collect comparable information for security and fraud detection purposes.

If you have any questions about cookies or to generally find out more about cookies, visit this site.

Your Choices
Cookies

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Note, however, that if you reject our request to use cookies or turn cookies off, you may be unable to access certain parts of the Sites and you may not be able to benefit from the full functionality of the Sites. To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org, and/or www.youronlinechoices.com.

Do Not Track

Your browser may offer you a “Do Not Track” (“DNT”) option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites and platforms. There is no universally agreed-upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

Communication Preferences

With your consent, the Company communicates with you via a variety of digital media, including emails and text messages. (Mobile message and data rates from your carrier may apply). To help us make e-mails more useful and interesting, we use pixels that enable us to see if you open e-mails from us, if your computer supports such capabilities. You can opt out of receiving emails from us at any time. To manage your communications preferences with the Company — or to opt out of communications entirely — please unsubscribe at the bottom of our emails or contact us at concierge@mitowimgmt.com

Analytics

We use Google Analytics to help us understand how our customers use the Sites. You can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.

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