Privacy Policy (GDPR Compliant)

The following Online Privacy informs how the personally identifiable information that you voluntarily provide while engaging with this website site is collected, stored and processed. This includes use cases such as opting in to receive a free resource from us, registering for a webinar, live event, or purchasing any of our products or professional services.

Introduction

This privacy policy outlines what information (“PERSONAL DATA”) is collected from you (“SUBSCRIBER”) and how that information is handled by Athena CXO Solutions LLC (the “COMPANY”). All is done in accordance with the General Data Protection Regulation (GDPR), which went into effect on May 25, 2018.

GDPR is a legislation that is relevant to all internet-based businesses who serve a global community, where there are no borders. Website visitors, subscribers and customers can originate from any country internationally. We want to be good stewards of the data we collect and protect, so we adopt responsible business practices and software configurations to achieve compliance with the country who has the strictest privacy regulations at this time.

If you have any questions about privacy practices, please contact the us using the support/contact us information below. You can use the contact link on your online site or email support@zenler.com to get the contact information of the Website instructors and administrator(s).

Summary

The COMPANY provides various ways for you to add your personal information to its database. By clicking on “Submit” “Sign-up” “Buy now” “Purchase” and or any other button that has a similar meaning, you are providing your explicit consent to be added to the COMPANY’s communication system. The COMPANY may use any reasonable means of communicating with you based on the information you provide. You may opt-out of this at any time by clicking on the “unsubscribe” button included on all email communication. The COMPANY respects the privacy concerns of the users of its website, https://www.athenacxo.com and the services and or goods provided there (the “SITE”). The COMPANY provides this privacy statement to explain what information is gathered during a visit to the SITE and how such information may be used.

 Please also review the Terms of Use at https://www.athenacxo.com/terms, which also govern your use of this SITE.

Use of Information

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.

As a general policy, no personally identifiable information (“PERSONAL DATA”), such as your name, address, or e-mail address, is automatically collected from your visit to the SITE.

 ANY PERSONAL DATA COLLECTED BY THE SITE MUST BE VOLUNTARILY ENTERED BY THE SUBSCRIBER. We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this: Cookie Policy.  

NON-PERSONAL DATA is recorded by the COMPANY’S use of Google Analytics. The COMPANY uses the information collected and provided by Google Analytics to help understand where from its internet searches and traffic originates.  

PERSONAL DATA is information that specifically identifies you (name, email address, ship to/bill to address, phone number) and can be used to specifically locate you from within the COMPANY’S database and/or filing system.    

The SITE’S various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give the COMPANY contact information such as your:

• Name
• Email
• Phone Number  

Contact information submitted at the time of submission will be used by the COMPANY to:  

• mail the SUBSCRIBER the requested information from the COMPANY
• Email the SUBSCRIBER a weekly and or monthly newsletter from the COMPANY; the COMPANY believes in only sending communications when it has something of importance to send
• Grant the SUBSCRIBER access to the requested content from the COMPANY  

Where will my PERSONAL DATA reside online and for how long?
PERSONAL DATA submitted voluntarily by the SUBSCRIBER is held:

• Within the COMPANY’S Zenler's SITE and database;
• Until the SUBSCRIBER requests to be unsubscribed and or up to two years from the time of submitting, whichever comes sooner;
• The COMPANY will ask the SUBSCRIBER every two years if he or she wants to continue as a SUBSCRIBER to the COMPANY.

Legal Basis for Use of Information

COMPANY is legally processing SUBSCRIBER’S PERSONAL DATA based on the following:

• The SUBSCRIBER has given his or her explicit and voluntary consent to the COMPANY; and/or
• The COMPANY has a legitimate interest to process SUBSCRIBER’S PERSONAL DATA.

Use to Third Parties

PERSONAL DATA is never sold, leased, or shared with any third parties. A third party is a COMPANY outside of the SUBSCRIBER - COMPANY relationship.
 
We may receive personal data about you from various third parties and public sources as set out below. When a Third Party Service is enabled, we are authorized to connect and access Other Information made available to us in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. Third party integrations may include:

• Zapier.com: Integrations, Automation
• MailChimp.com: Mailing Service
• Google.com: Analytics, reCAPTCHA
• DigitalOfficePro.com: PowerPoint to HTML5 Technology
• SlideServe.com , SlideOrbit.com: Slide Hosting Service
• Facebook.com: Facebook Login, Meta Pixel
• Segment.io: Customer Data Management

Use of Credit Card Information

The COMPANY does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.

 All credit card information is handled by Stripe or PayPal.  

All transactions are handled using an SSL certificate from Cloudflare. This can be verified by looking at the URL in your Internet browser and making sure it begins with HTTPS:// and an icon of a lock. This is in contrast to HTTP://, which is not a secure connection.

Use Legal Obligations

The COMPANY may disclose SUBSCRIBER information in special cases when required by legal and/or law enforcement and only when required by law.

If the COMPANY has reasonable reason to believe that disclosing PERSONAL DATA held by the COMPANY is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the COMPANY’S rights or property, other users of the SITE, and/or anyone else that could be harmed by such activities, then the COMPANY will work with the appropriate and legitimate law enforcement and or legal authorities to make sure that the PERSONAL DATA is handled in accordance with the applicable laws.  

Subscribers' Rights

As a subscriber and or user of the SITE, you have the following rights:
  • Transparent information from the COMPANY regarding how they communicate and interact with the SUBSCRIBER 
  • The right to hear back from the COMPANY regarding any inquiry into SUBSCRIBER’S PERSONAL DATA 
  • The right to request correction of PERSONAL DATA from the COMPANY • Access to SUBSCRIBER’S PERSONAL DATA including knowing the purposes that the data is used for 
  • The right to request erasure from the COMPANY’S records provided that there are no overriding legal, public interest, or legitimate interests 
  • The right to a restriction on the processing of the PERSONAL DATA 
  • Data portability of PERSONAL DATA (having a record provided to you that is readable and commonly used that outlines the PERSONAL DATA that the COMPANY has on you) 
  • The right to object to processing of PERSONAL DATA (the COMPANY shall no longer process the SUBSCRIBER’S PERSONAL DATA unless the COMPANY demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the SUBSCRIBER or for the establishment, exercise or defense of legal claims) 
  • The right to file a complaint with the supervisory authority 
  • The right to unsubscribe at any time (withdraw consent) 

Profiling Personal Data

Profiling means any form of automated processing of PERSONAL DATA consisting of the use of PERSONAL DATA to evaluate certain personal aspects relating to a SUBSCRIBER, in particular to analyze or predict aspects concerning that SUBSCRIBER’S performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

The COMPANY DOES NOT ENGAGE IN ANY SORT OF PROFILING OF ITS SUBSCRIBERS BASED ON PERSONAL DATA.

Children Under Age 13

The COMPANY recognizes the special obligation to protect PERSONAL DATA obtained from children age 13 and under.

 IF YOU ARE 13 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY.  

If the COMPANY discovers that a child age 13 or younger has signed up on the SITE and or provided the COMPANY with PERSONAL DATA, the COMPANY will delete that child’s PERSONAL DATA from its records. The COMPANY nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:

  • Teach kids never to give personal information, unless supervised by a parent or responsible adult. This includes name, address, phone, school, etc. 
  • Know the sites your kids are visiting and which sites are appropriate. 
  • Look for website privacy policies. Know how your child’s information is treated. 
  • Visit the Federal Trade Commission’s (FTC) site for more tips on protecting children's privacy online. 

Use of Cookies

Cookies are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes. Cookies make using the COMPANY’S SITE easier by saving your passwords and preferences for you. These cookies are restricted for use only on COMPANY’S SITE, and do not transfer any PERSONAL DATA to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions.

 If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the SITE may not function properly or may be considerably slower.

Malware/Spyware/Viruses

Neither the COMPANY nor the SITE knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.
 

Links to External Sites

The COMPANY is not responsible for the content or practices of third party websites that may be linked to the SITE. The COMPANY is also not responsible for any information that you might share with such linked websites. You should refer to each website’s respective Privacy Policy and practices prior to disclosing any information.
 

Bulletin Boards and Chat Areas

The COMPANY does not provide any kind of a public forum or chat feature. Guests of the SITE are solely responsible for the content of messages they post on the COMPANY’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., user name, email address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features.
 

Opt Out or Removal of Your Information

The SITE provides the SUBSCRIBER the opportunity to opt-in to receive communications from the COMPANY at the point(s) where PERSONAL DATA information is required to be voluntarily entered by the SUBSCRIBER. The SUBSCRIBER always has the option of removing their PERSONAL DATA from any communications list in order to discontinue any such future communications.

 In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the COMPANY that you no longer wish to receive.  

If you are unsuccessful in completing the instructions specified in any such communication, please email the COMPANY at hello@athenacxo.com and simply request to unsubscribe.

Marketing Communications

Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if you made a purchase or asked for information from us about our goods or services or you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.

Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us via the contact us form at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

Additional Disclosures Regarding Your Personal Data

We may have to share your personal data with the parties set out below:

Online Course platform provider Zenler.com who will be data processor of your data. We have entered into a data processing addendum with Zenler to process your data. Other companies in our group who provide IT and system administration services and undertake leadership reporting. Service providers who provide cloud infrastructure, video hosting, live video platforms, email provider, IT and system administration services.

 Amazon
Sendgrid
FileStack
Vimeo
Zoom

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. Government bodies that require us to report processing activities. require reporting of processing activities in certain circumstances. Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Transfer of Customer Information

Customer lists and information are properly considered assets of a business. If COMPANY merges with another entity, or if it sells its assets to another entity, the COMPANY’S customer list and information would be included among the assets transferred.

 SUBSCRIBER would be given the opportunity to unsubscribe both before and after the sale.

International Transfers

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

Our Online course platform Zenler provider based in the UK is our data processor and we have entered into data processing agreement for the processor to protect your personal data. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Where we use providers based in the United States (for example Amazon, Sendgrid) we may transfer data to them where we have signed data processing addendums for the provider to provide protection of data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email support@zenler.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Security for all PERSONAL DATA is extremely important to the COMPANY. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while the COMPANY strives to protect SUBSCRIBER’S PERSONAL DATA, the COMPANY cannot ensure or warrant the security of any PERSONAL DATA the SUBSCRIBER transmits via the internet. By transmitting any such information to the COMPANY, SUBSCRIBER accepts that he or she does so at their own risk.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:


  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  •  Right to withdraw consent. 

You can see more about these rights at:

If you wish to exercise any of the rights set out above, please reach us via the contact information below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Third Party Links

We may include links to third-party websites, addons and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

Age Limitations

By providing us with your data, you warrant to us that you are over 13 years of age.

How to Contact Us

You can contact Athena CXO Solutions at any time if you have any questions about this Privacy Policy or our practices, or if you are seeking to exercise any of your statutory rights.

Mail:      Washington DC (email for physical address)  
Email:   info@athenacxo.com      

Information provided by you via general email inquiries to the COMPANY such as your email address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.

Data Protection Authority

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us by email on info@athenacxo.com and support@zenler.com first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us via the support/contact us form OR update your profile in your account.

Your Acceptance of These Terms

By using the SITE, the SUBSCRIBER accepts the policies and restrictions set forth in this Online Privacy Policy. If you do not agree to this policy, please do not use the SITE. This Online Privacy Policy may be revised from time to time by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Online Privacy Policy to which you are bound.

 Last Updated:  November 10, 2024

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