PRIVACY AND COOKIE POLICY

Welcome to Metamorphany Changemakers, a principal component of the Gaia ecosystem.

The Gaia ecosystem is provided to you by Gaia Holistic Coaching & Learning, formerly known as Gaia Innovations Inc., (“Gaia”), a social purpose corporation (“Gaia”, “Metamorphany,” “we,” “our,” “us”) with collaborators and partners in Canada, France, Germany, Netherlands, and Spain. Gaia operates the websites and other digital services located at the URLs www.metamorphany.org, www.metamorphany.com, www.leilanicura.com, together with any other websites, services or applications branded as, provided by, facilitated by, and/or supported by Gaia, including, without limitation, ecosystem partners Metamorphany, Metamorphany Changemakers, Metamorphany Solutions, Gaia Innovations, Morpheus, Youth Driven Innovation, STUDIO.WHY Deutschland, LeilaniCura, MichaelSmits, Peace Agora, KaiSmits and PH5VE Coaching & Consultancy (collectively, as defined in our Terms of Use), referred to together in this Privacy and Cookie Policy as “our digital Purpose Services”).

If you have any questions about this Privacy and Cookie Policy, please contact us at notify[at]gaia-innovations.com with “Privacy and Cookie Policy” in the subject line.

General Statement About GAIA, Data, and Privacy

Our primary goals in collecting personally identifiable information are to provide you with the products and services made available through our digital Purpose Services, including, but not limited to, provision of our websites, the Content, courses, and training programs, communicating with you, and managing your registered user account, if you have one, and to facilitate the publication of your own User Generated Content (as defined in our Terms of Use). In general, Gaia collects Personal Data when you register with Gaia, make a purchase (including free purchases), when you use Gaia digital Purpose Services and when you visit Gaia digital pages or pages related to the Content posted on Gaia digital pages. That information is used to fulfill your requests for products and services, to conduct research, to contact you, to contact those who view, use and/or purchase your User Generated Content, and to improve Gaia’s digital Purpose Services generally.

1. Scope and Privacy Policy Overview

Gaia Holistic Coaching & Learning, formerly known as Gaia Innovations Inc., (“Gaia”) is the company that runs our digital Purpose Services. This is the Privacy and Cookie Policy for the Metamorphany Changemakers services found at www.metamorphany.org and www.metamorphany.com. Gaia owns, operates, or provides access to, interactive websites, mobile, and connected applications, and other online interactive features and services, including, but not limited to, emails, newsletters, podcasts, courses, workshops, webinars, labs, and other online coaching and training programs, and promotional giveaways (collectively “digital Purpose Services”).

This Privacy and Cookie Policy explains how we collect, use, disclose, manage and share your personal information (“Personal Information”) that you provide to us when using our digital Purpose Services or otherwise, as well as our privacy practices. This Privacy and Cookie Policy applies, without limitation, to any individual or entity that (i) uses our digital Purpose Services (including any employees, contractors, or other users: “Users”), (ii) creates an Account (as defined in our Terms of Use), or (iii) otherwise provides any personal information to us.

WHEN YOU ACCESS OR USE OUR DIGITAL PURPOSE SERVICES, OR OTHERWISE PROVIDE ANY INFORMATION TO US, YOU AGREE TO THIS PRIVACY AND COOKIE POLICY, INCLUDING THE MANNER IN WHICH WE USE YOUR INFORMATION, WHETHER OR NOT YOU HAVE AN ACCOUNT WITH GAIA. IF YOU DO NOT AGREE TO THIS PRIVACY AND COOKIE POLICY, OR TO ANY CHANGES WE SUBSEQUENTLY MAKE TO THIS POLICY, YOU MUST IMMEDIATELY STOP USING OUR DIGITAL PURPOSE SERVICES OR OTHERWISE PROVIDE ANY INFORMATION TO US.

Our digital Purpose Services contain links to other websites and digital services. This Privacy and Cookie Policy does not apply to information collected on or through any such third-party websites. We are not responsible for the privacy and cookies practices of such third parties or the content of their websites and digital services. Such third parties have their own privacy and cookies policies and you should review those policies to determine their privacy and cookies practices.

Except as otherwise noted in this Privacy and Cookie Policy, Gaia is a data controller (as that term is used under the EU General Data Protection Regulation (“GDPR”)), which means that we decide how and why the information you provide to us is Processed. This Policy explains how we use the information you provide to us to be able to continue to provide the digital Purpose Services.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully and to regularly check this page to review any changes we might make.

2. Choice

It is always a User’s choice whether or not to provide Personal Information. However, if a User chooses not to provide requested Personal Information, that User will not be able to use certain features of our digital Purpose Services. We set out in detail below the information that we collect about Users and Users’ use of our digital Purpose Services. Gaia does not intentionally collect things like protected health information, financial information, date of birth, social security or other government-issued identification numbers, and other sensitive personal information from Users.

THIS POLICY DOES NOT SET OUT THE INFORMATION COLLECTED BY THE THIRD-PARTY PRODUCTS AND SERVICES USED IN OUR DIGITAL PURPOSE SERVICES NOR THE INFORMATION COLLECTED BY THE INDIVIDUAL STARTUPS THAT GAIA AND/OR METAMORPHANY IS MENTORING AND COACHING THROUGH THE USE OF OUR DIGITAL PLATFORM — THIS INFORMATION IS SET OUT IN THE PRIVACY POLICIES MADE AVAILABLE BY THE INDIVIDUAL PARTIES. ANY ACCESS REQUESTS OR SIMILAR FROM MEMBERS OF THIRD-PARTY TOOLS AND/OR ANY OF THE STARTUPS WE MENTOR AND COACH WILL BE DIRECTED TO THE PRIVACY OFFICER OF THE RELEVANT THIRD PARTY.

We may be contacted using the contact details set out at the top of this policy. Any request e-mailed to us at notify[at]gaia-innovations.com will be responded to within the reasonable timeframe specified in section 18.

3. Categories of Information We May Process

We may Process: your personal details (such as your name); demographic data (such as your age); your contact details (such as your address); records of your consent; purchase details; information about your interactions with our content or advertising; and any views or opinions you provide to us. We may also Process information about you from your use of our digital Purpose Services (such as the type of device you are using, the internet service provider, your IP address, etc.), including your interactions with content and advertising on our digital Purpose Services.

“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. All of this activity will take place in Canada, the United States (U.S.), and the European Union (EU).

“Multi-Site Data”, “MSD" means any Personal Information that is shared between more than one website and/or digital purpose service within the Gaia ecosystem of digital Purpose Services. This is enabled and agreed upon by the user through the creation of one unique Gaia Account Number.

Gaia is a company federally registered in The Netherlands with collaborations and partnerships in Australia, Canada, and multiple EU countries, including France, Germany, and Spain. However, the servers that run Metamorphany and Gaia’s digital Purpose Services may reside in Canada, the United States (U.S.), or the EU. If you reside outside Canada, the U.S., or the EU, your personally identifiable information will be transferred to Canada, the U.S., or the EU, and processed and stored there under Canadian, U.S., or EU privacy standards. By visiting our digital Purpose Services and providing information to us, you consent to such transfer to, and processing in, Canada, the U.S., or the EU. Gaia may transfer your Personal Data to other countries where it does business.

3.1  Information Collected

We may Process the following categories of Personal Information about you:

• Personal details, including but not limited to the following: your name, your username or login details, your password, and your areas or topics of interest.
• Demographic information, including but not limited to the following: age, date of birth, and language preferences.
• Your contact details, including but not limited to the following: postal address(es); telephone and/or mobile number(s); email address(es); and your public social media handles or profile(s).
• Consent records, including but not limited to the following: records of any consents you may have given, together with the date and time, means of consent, and any related information (such as the subject matter of the consent).
• Purchase and payment details, including but not limited to the following: records of purchases and prices, subscription details, invoice records, payment records, payment method(s), credit/debit card, and other billing information, including card numbers cardholder or accountholder name, billing address(es), payment amount, and payment date.
• Interactive Features. We and others who use our digital Purpose Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting, views and opinions functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

We may also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:

• Information about your use of our digital Purpose Services, such as usage data and statistical information, which may be aggregated and/or anonymized so that it is not linked to you.
• Browsing history including the websites or other services you visited before and after interacting with our digital Purpose Services.
• Searches for and interactions with e-commerce opportunities, such as offers contained in our digital Purpose Services
• Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device, derived from the IP address of such computer or device (“GeoIP Data”).
• Service Provider Information: Information about the mobile or internet service provider you are using with your device to access our digital Purpose Services and/or send us messages, including name and Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
• Information collected through the use of cookies, Javascript, pixel tags, and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, our digital Purpose Services, content, and ads on third party websites, applications, platforms and other media channels (“Channels”), and (ii) your interaction with emails including the content and ads therein (collectively, “Online Data”).
• Device type, settings, and software used.
• Messages: The date, time, and content of any messages you send to us;
• Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps, and/or clickstream data, including any clicks on customized links.
• Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
• Pixel Tags, also known as clear GIFs, beacons, spotlight tags, or web bugs, which are a method for passing information from the user’s computer to a third-party website.
• Local Shared Objects, and Local Storage, such as HTML5.
• Embedded Scripts, which are programming codes designed to collect information about your interactions with our digital Purpose Services by temporarily downloading onto your device from our web server or a third party with whom we work. Embedded scripts are only active while you are connected to our digital Purpose Services and are deleted or deactivated thereafter.
• Mobile analytics to understand the functionality of our mobile applications on your phone.
• Job Applications. We may post job openings and opportunities on our digital Purpose Services. If you reply to one of these postings by submitting your application, CV, and/or cover letter to us, we will collect and use your information to assess your qualifications.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• The information listed above which we aggregate and/or anonymize so that it is not linked to you.
• Any Personal Information that may be aggregated as MSD linked between different of our digital Purpose Services through the creation of one unique Gaia Account Number by the User.

Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.

4. Sensitive Personal Information

We do not seek to collect or otherwise Process your Sensitive Personal Information. Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable law. Our digital Purpose Services are not intended for use by children under the age of 13. If you are a minor and are 13 years of age or older, you must have your parent or legal guardian’s permission to use our digital Purpose Services.

We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business.

Where it becomes necessary to Process Sensitive Personal Information under GDPR or any other regulation, we would rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
• Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
• Establishment, exercise, or defence of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise, or defence of legal rights; or
• Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.

For the details of the Minimum Age Requirements for our digital Purpose Services, please refer to section 4 of our Terms of Use.

Gaia and/or Metamorphany reserves the right to refuse service to anyone at any time without notice for any reason.

5. How We Collect or Create Information

We may collect or obtain User Information about you: directly from you (such as when you contact us); in the course of our relationship with you (for example, if you make a purchase, free or otherwise); when you make your Personal Information public (for example, if you make a public post on our digital Purpose Services or about us on social media); when you download, install, or use any of our digital Purpose Services; when you visit our digital Purpose Services; when you register and create an Account to use any part of our digital Purpose Services; or when you interact with any third party content or advertising on our digital Purpose Services.

We may also receive User Information about you from third parties (such as social network services or billing processors). We may also create User Information about you, such as records of your interactions with us.

Gaia is not responsible for Personal Information you volunteer about yourself in public areas of our digital Purpose Services, such as the Interactive Features. This Policy does not cover the practices of third parties who may provide information about you to Gaia and/or Metamorphany.

Collection of User Information: We may collect User Information about you from the following sources:

• Data you provide: We may obtain your Personal Information when you provide it to us across our digital Purpose Services (for example, where you sign up for emails or newsletters; register for a membership or create a profile or Account on any part of our digital Purpose Services; enter a promotional giveaway; participate in surveys; contact us via email, telephone or by any other means; or purchase a subscription, etc.).
• Business relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (for example, if you make a purchase from us).
• Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (for example, we may collect information from your social media profile(s) if you make a public post about us).
• Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our digital Purpose Services.
• Content and advertising information: If you choose to interact with any third-party content, User Generated Content, or advertising on the Channels, we may receive User Information about you from the relevant third party.
• Third-party information: We may collect or obtain your Personal Information from service providers and third parties who provide it to us and combine such information with information we have collected about you. This may include channels such as social network sites or services (such as Twitter, Facebook, etc.). We may also obtain information about purchases you make from our billing processors (such as Stripe, Wise, N26, PayPal or Square), including information about the Products and/or Services you own on our digital Purpose Services. To the extent we combine such third-party sourced information with Personal Information we have collected about you on our digital Purpose Services, we will treat the combined information as Personal Information under this Privacy and Cookie Policy.

Please note that Gaia is not responsible for the information you volunteer about yourself in the discussions in certain public areas of our digital Purpose Services or information that you choose to make public in your member profile or other areas of our digital Purpose Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page.

To request the removal of your Personal Information from these areas, please see Section 18 in this Privacy and Cookie Policy for further details. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.

This Privacy and Cookie Policy does not cover the practices of third parties, including those that may disclose information to Gaia. We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices.

We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks.

6. Purposes for Which We May Process Your Information

We may Process User Information for the following purposes: providing our digital Purpose Services to you; communicating with you; providing advertising to you on the Channels; analyzing engagement with our audience; observing user engagement and purchase activity across our digital Purpose Services and Channels; marketing our services and offerings to current and prospective customers; managing our IT systems; financial management; conducting surveys; ensuring the security of our systems; conducting investigations where necessary; compliance with applicable law; and improving our digital Purpose Services.

The purposes for which we may Process User Information, subject to applicable law, include:

• Provision of our digital Purpose Services to You: providing our digital Purpose Services to you from Gaia or its partners including (i) offering of promotional giveaways, (ii) processing of your payment information for your purchases or subscriptions, (iii) management of your account, (iv) offering promotional and marketing information to you, and (v) customer support and relationship management.
• Offering and Improving our digital Purpose Services: operating and managing our digital Purpose Services for you; providing personalized content to you; communicating and interacting with you via our digital Purpose Services; identifying issues with our digital Purpose Services and planning improvements to or creating new Services; and notifying you of changes to any of our digital Purpose Services.
• Surveys: engaging with you for the purposes of obtaining your views on our digital Purpose Services.
• Communications: communicating with you via any means (including via email or social media) regarding information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 7 below.
• Advertising: providing advertising based on your interests and interactions with our digital Purpose Services and Channels, including using User Information to serve you advertisements on the Channels. For further information, please see Section 7 below.
• Audience Engagement: identification and development of audience engagement, advertising, and promotional strategies on various platforms and channels, both within our digital Purpose Services and on Channels.
• User Engagement and Purchases: tracking purchase traffic and activity across our digital Purpose Services and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
• Fraud Prevention: Our digital Purpose Services may use third-party fraud prevention software designed to prevent your credit card and other Personal Information from being used for a fraudulent purchase through our digital Purpose Services. Such software may work by analyzing user behaviour and detecting patterns that indicate fraud, and may also involve a third party tracking your activity over time and over a network of sites.
• Marketing to Customers: We may market to current and prospective customers and their employees who have indicated an interest in doing business with, or have previously conducted business with, Gaia in order to further generate and promote our business. Such efforts include sending marketing emails to drive the use of services offered by Gaia.
• IT Administration: administration of Gaia’s information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
• Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
• Financial Management: general business and financial management purposes, including: economic, financial, and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements
• Investigations: detecting, investigating, and preventing breaches of policy, and criminal offences, in accordance with applicable law.
• Legal Proceedings: establishing, exercising, and defending legal rights.
• Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of our digital Purpose Services when we have grounds to believe that the user is in violation of our Terms of Use or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety, or security of Gaia, any of our users, or the public, or to respond to an emergency.

7. Direct Marketing

We may Process your User Information to contact you via email or other methods of communication to provide you with information regarding our digital Purpose Services that may be of interest to you. We may send information to you regarding our digital Purpose Services, upcoming promotions, and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any such emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other digital Purpose Services you have requested or for additional emails you have signed up for.

Please note that we automatically opt Users into receiving emails when Gaia and/or Metamorphany publishes a new version and/or promotional giveaways of Master Content and/or User Generated Content, both including, but not limited to podcasts, courses, workshops, webinars, labs, and other online coaching and training programs, and Gaia and/or the Content Holder chooses to send “Release Notes” to Users who have purchased the Product or Service. Gaia, Metamorphany, and all our ecosystem partners are committed to the Lean Publishing process, and we believe automatically opting Users in to receive such emails is in their best interest, as it is useful for Users to know when a Product or Service has been updated. You may opt out of these emails individually (for example, you can opt out of receiving these emails from a specific category of products and services) or collectively (meaning you can opt out of all emails) in your account settings.

8. Cookies, Similar Technologies, and Online Behavioural Advertising

We may Process your User Information by placing or reading Cookies and similar technologies on the Services and Channels.

8.1 Cookies

We may gather information about your computer and your user behaviour with the use of cookie files. A cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic. Cookies allow web applications to respond to you as an individual, tailoring operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

All computers have the ability to automatically accept or decline cookies. This can be done by activating the setting on your browser which determines how to deal with cookies.

If you want to know more visit this website: http://www.aboutcookies.org.uk

8.1.1 Cookie Data

Depending on how you’re accessing our website or any of our other digital Purpose Services, we may use “cookies” (small text files sent by your computer each time you visit our website, unique to your computer or your browser) or similar technologies to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you or your browser deletes them). For example, we may use cookies to store your previous visits, preferences or other settings so you don‘t have to set them up every time you visit this website. Some of the cookies we use are associated with this website (including personal information about you, such as the email address you gave us) and other cookies are not.

In addition to log data, we may also collect information about the device you’re using, including what type of device it is, what operating system you’re using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. To learn more about what information your device makes available to us, please also check the policies of your device manufacturer or software provider.

Other online systems such as social media, website plug-ins, and function providers may well use cookies and collect user data. These providers/companies will have their own control systems and policies, and they should be consulted directly. Please get in touch if you have any questions regarding these and we will do our best to satisfy your queries.

8.2 Tracking and third parties

Certain technologies enable us to assign a unique identifier to you and relate information about your use of our digital Purpose Services to Other Information about you. We and our partners also use these technologies to analyze trends; administer our digital Purpose Services; collect and store information such as user settings and anonymous browser identifiers; supplement our server logs and other methods of traffic and response measurement; gather demographic information about our user base, and; to improve our understanding of traffic on our digital Purpose Services.

Certain third parties may collect information about you for online behavioural advertising purposes in order for you to receive relevant interest-based advertising on our digital Purpose Services and on other websites, platforms, and media channels. We may use Online Data as well as other User Information to send you online behavioural ads we believe are more relevant to your interests.

Gaia and its partners may use cookies and other tracking technologies to analyze trends, administer Services, track users’ movements around our digital Purpose Services and on third-party sites, devices, and applications, and gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our digital Purpose Services.

Tracking technologies on our digital Purpose Services may be deployed by Gaia and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content and advertising.

When you receive email messages or newsletters from us, we may use web beacons, embedded scripts, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information, and/or to aggregate that information with other data we collect to use for some or all of the purposes outlined in this Privacy and Cookie Policy.

We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, IP addresses, and Local Storage such as HTML5 to analyze trends; administer our digital Purpose Services; collect and store information such as user settings and anonymous browser identifiers; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around our digital Purpose Services; gather demographic information about our user base, and; to improve our understanding of traffic on the Services and visitor behaviour. We may receive reports based on the use of these technologies by these third-party companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing Local Storage.

We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices, and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.

Certain third parties may collect information about you for Online Behavioural Advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on our digital Purpose Services and on other websites, platforms, and media channels. OBA is also referred to as interest-based advertising.

These third parties may use Online Data as well as other User Information to send you OBA. For example, if you read an article about a particular subject on our digital Purpose Services, the third party may use cookies to later serve you an advertisement for a particular product or service related to the viewed article. These third-party vendors may connect information about pages you visit on our digital Purpose Services with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of our digital Purpose Services or on another Channel.

The specific providers we use for OBA are subject to change. Currently, we do NOT use any such services. If we do, we will list them here or somewhere relevant on our Site. For more details about OBA, MSD, and opting out, see Section 16 below.

9. What is the Lawful Basis for Processing Personal Information

We may Process your User Information where: you have given your consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.

In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

• Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
• Contractual necessity: We may Process your User Information where the Processing is necessary in connection to any contract that you may enter into with us;
• Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
• Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
• Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating, or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

10. What Information We Disclose to Third Parties

We may disclose your User Information to: legal and regulatory authorities; our external advisors; parties who Process User Information on our behalf (“Processors”); any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting, or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on the Services.

We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:

• Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• Outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
• Third-party Processors (such as analytic providers, data centres, etc.), located anywhere in the world, subject to the requirements noted below in this Section 10;
• Any relevant party, law enforcement agency, or court, to the extent necessary for the establishment, exercise, or defence of legal rights;
• Any relevant party for the purposes of prevention, investigation, detection, or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
• Any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation);
• Any relevant third-party provider, where our Channels use third-party advertising, plugins, or content. If you choose to interact with any such advertising, plugins, or content, information about your activities on the Channels to provide you with targeted advertising based on your interests may be shared with the relevant third-party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
• Any sponsors of promotional giveaways. The registration data for such events is to be used by us as part of User Information and may be shared with the sponsor and others, subject to this Policy and the sponsor’s privacy policy. We may also share your information with third-party vendors involved in the administration of such events. For promotional giveaways, please read the official rules or Terms of Service carefully before you submit your information; and
• To third parties whose practices are not covered by this Privacy Policy (for example, third-party providers of goods and services, marketing and advertising companies and agencies, analytics providers, and retailers).

Certain functionalities on our digital Purpose Services may permit interactions that you initiate between our digital Purpose Services and certain third-party services (“Third Party Features”). Examples of Third-Party Features include “liking” or “sharing” content over social media platforms through our digital Purpose Services, or linking your Gaia account to a third-party service, should we offer this functionality. If you use Third Party Features, both Gaia and the third party may have access to certain information about you and your use of our digital Purpose Services and the third party service. For example, if you post information on a third-party service that references our digital Purpose Services (such as by using a hashtag associated with Gaia and/or Metamorphany in a tweet or status update), your post may be used on or in connection with our digital Purpose Services or that third party service. We are not responsible for the practices employed by websites linked to or from our digital Purpose Services, nor the information or content contained therein or any information third parties obtain through your use of Third Party Features. Please remember that when you use a link to go from our digital Purpose Services to another website, our Privacy and Cookie Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

With respect to surveys, should Gaia choose to undertake them, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise, we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Gaia advises users of the possibility of such disclosure at the time they take the survey, Gaia reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

Some of our advertisers may use third-party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Channels. Often, these third-party advertising companies employ cookies and other technologies to measure the effectiveness of website, app, and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on our digital Purpose Services. We may also engage third-party providers to assist with the segmentation of this data.

We may engage third-party providers to assist with the collection, storage, and segmentation of Online Data. Such providers are required to maintain the confidentiality of this information. These third-party providers may collect User Information from our digital Purpose Services for their own purposes, such as to monitor fraud around the web.

If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.

Our digital Purpose Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

11. International Transfers of Information

We may transfer your Personal Information to recipients in other countries.

Because of the international nature of our business, we may need to transfer your User Information within the Gaia ecosystem of companies and digital services, and to third parties, as noted in Section 10 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements than those that apply in the country in which you are located.

Gaia is a Dutch/Canadian company and may not participate in the E.U.-U.S. Privacy Shield Framework. However, Gaia is committed to the principles upon which the framework is founded.

In certain situations, Gaia may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you are a European individual with a privacy-related complaint, concern or question about Gaia’s privacy practices, please contact us by writing to notify[at]gaia-innovations.com with “Privacy and Cookie Policy” in the subject line. We will respond to your request within the timeframe defined in section 18.

Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information, we do so on the basis of standard contractual clauses.

Please note that when you transfer any Personal Information directly to a Company entity established outside the EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process your Personal Information, from the point at which we receive the data, in accordance with the provisions of this Privacy and Cookie Policy.

12. Data Security

We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us is sent securely.

13. Data Accuracy

We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us of is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

14. Data Minimization

We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to our digital Purpose Services.

15. Data Retention

We take every reasonable step to ensure that your User Information is only retained and Processed for as long as it is needed, for the purposes set out in this Policy unless applicable law requires a longer retention period.

Gaia, Metamorphany, and the other Purpose Services in the Gaia ecosystem are services that are used primarily to:

• Receive mentoring, coaching, and training by experienced mentors, coaches, and other relevant professionals in every facet of Inner Development, Sustainable Development, doing Business for Good and the development and deployment of Technology for Good. Aimed at developing an entrepreneurial innovative and agile mindset with a holistic view, and the development of new and experienced purpose-driven changemakers and startups towards exponential positive and holistically sustainable impact.
• Facilitate and engage in online Collaborative Workshops, Innovation/Futures/Solution Labs, Cultural Transformation Labs, Workplace Happiness & Well-being Labs, Inner Development training & practices, and other Transformative Purpose-driven initiatives that help accelerate the realization of the UN Sustainable Development Goals (“SDG”s), in particular goals 3 Good Health and Well-being, 4 Quality Education, 5 Gender Equality, 9 Industry, Innovation and Infrastructure, 10 Reduced Inequalities, 11 Sustainable Cities and Communities, 12 Responsible Consumption and Production, 13 Climate Action, 14 Life Below Water, 15 Life On Land, 16 Peace, Justice and Strong Institutions, and 17 Partnerships for the Goals, through the pillars of Education (and reform of Education and Learning), Regenerative Leadership, Food, Healthy Living, Well-being & Happiness, and Inner Development, with a strong focus on teachers, social workers, parents, city-representatives, youth and young adults.
• Buy, review, read, and engage in articles, postings, podcasts, books, and courses that are aimed at the realization of a better future, increased collaboration, co-designing and co-creation, awareness creation around and realization of the SDGs, and an overall increase of (Mental) Health, Well-being, Happiness, Equity and Fairness within learning communities, cities, at work and in our global societies.

When a user buys a subscription, podcast, book, or a course, it is made available to them through our platform or, in some cases, the platforms of our partners or third-party providers that we work with. Some products that are subscription-based and/or time-restricted may be made available to the users for an agreed period of time, which is communicated at the time of purchase, whether that purchase is paid or free. With some products and materials, people who buy these learning materials expect them to be available for an indefinite period of time, just like, for example, a person who buys a physical book or audio recording and puts it on their bookshelf expects that book or CD to be there the next time they look. As such, we may not delete user information related to such ‘indefinite’ purchases, whether those purchases are paid or free, unless users ask us to delete the information.

Any relevant information related to a purchase, whether that purchase is paid or free, may be kept as long as necessary to comply with potential legal requirements, including anti-money laundering investigations, tax investigations, fraud investigations, copyright violations, or any potential legal challenges or other proceedings.

To be clear, this means that even if you request to delete your account, if you have sold a Product or User Generated Content as a Content Holder through any of Gaia’s digital Purpose Services, whether that purchase is paid or free, we will keep a copy or copies of the Product or Products you have sold, and any other user account information related to it that may be required in potential future legal or other proceedings, including, inter alia, contact information, such as your email address.

Furthermore, if you have made a Gaia, Metamorphany, Morpheus, LeilaniCura and/or PeaceAgora purchase (free and/or paid), and you request to have your account deleted, we reserve the right to retain any information that may be required as part of any potential future legal or other proceedings, including, inter alia, contact information, such as your email address.

Except as may be set forth in this Privacy and Cookie Policy, Online Data related to OBA is retained by Gaia for not more than 180 days after which it shall expire, subject to certain conditions. However, the 180-day period may commence again if the same user subsequently visits or interacts with an ad, email, the digital Purpose Services, or a Channel.

16. What Can I Do to Control My Information?

You can directly take steps to change your preferences for newsletters, OBA, and MSD as outlined in this section.

If you are an EU resident, you may have certain rights including: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Information; the right to object to the Processing of your Personal Information and MSD and/or object to our way of processing your data; the right to have your Personal Information transferred to another controller; the right to withdraw the consent you have given at any point in time; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.

You may directly take steps to change your preferences as follows:

You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive, or in your account settings. Please allow five to ten business days for changes to take effect.

On some parts of our digital Purpose Services, member service-related communications are an integral part of such services to which you subscribe and you may continue to receive emails as part of that particular portion of our digital Purpose Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe from each email address you have provided.

We may send you push-notifications from time to time in order to update you about any events or promotions that we may be running within any of our digital Purpose Services within the Gaia ecosystem of services. Under those circumstances, we will provide you with the ability to turn these off by adjusting the permissions on your mobile device. Please note that your opt-out is limited to the device used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or Gaia’s ongoing business relations.

There are a variety of tracking technologies that may be included in mobile applications. These are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps. You can stop all collection of information via our mobile applications by uninstalling them. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device (which is usually located in the Settings area of your device).

If we offer you the opportunity to link your Gaia account with certain third-party services, you will be provided with the ability to unlink your accounts at any time by visiting your Gaia account settings. Please note that unlinking your accounts will not affect any information previously shared through the linking, and Gaia may continue to use and share that information in accordance with this Privacy and Cookie Policy. Gaia is not responsible for any third-party data practices, and we recommend that you carefully review their online policies.

You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use our digital Purpose Services, you may not be able to use all of the features, functions, or services available on our digital Purpose Services.

For California Residents: in accordance with the California Online Privacy Protection Act, we may collect Personal Information about your online activities when you use our digital Purpose Services. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals. California’s “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request in writing to notify[at]@gaia-innovations.com with “Privacy and Cookie Policy” in the subject line.

For EU Residents: GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure, and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us at notify[at]gaia-innovations.com with “Privacy and Cookie Policy” in the subject line. If you are an EU resident and have any unresolved privacy concerns that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

17. Terms of USE

For more information concerning your use of our digital Purpose Services, please visit our Terms of Use, which are incorporated by reference into this Privacy and Cookie Policy.

We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

18. Contact Details

If you have any comments, questions, or concerns about any of the information in this Policy, or any specific requests as California or EU Residents, or want to invoke one or more of your privacy rights, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact us by email at notify[at]gaia-innovations.com with “Privacy and Cookie Policy” in the subject line.

Any request e-mailed to us at notify[at]gaia-innovations.com will be responded to within 30 days.

19. How this Privacy Policy May Change

We may change this Privacy and Cookies Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Privacy and Cookies Policy or our data collection and use practices, we will indicate on our websites that our Privacy and Cookies Policy has changed prior to the change becoming effective. The then-posted version of the Privacy and Cookies Policy supersedes all prior versions. Your continued access to or use of any of our digital Purpose Services shall be deemed your acceptance of the Privacy and Cookies Policy.

We urge you to come back to this web page and review this Privacy and Cookies Policy regularly so that you remain aware of the terms and conditions that apply to you.

20. List of Third-Party Services with Whom Personal Information May Be Shared

This is a list of third-party services we use in accordance with our legitimate interests, including internal administrative purposes. This list is subject to change and we recommend you revisit it from time to time. We have provided links so you can easily see what these services do and read the privacy policies they provide.

We will also share data with legal authorities and other relevant agencies where required for legitimate purposes, including compliance with the law and prevention of fraud or other legal activities.