Privacy Policy

Privacy and Cookies Policy

This Privacy Policy governs your use of Lauren Clayton (referred to below as “the Websiteâ€). By using the Website, you accept the terms and conditions in full and without reservation. If you disagree with the terms and conditions or any part of the terms and conditions, you must not use the Website.

You must be at least 18 [eighteen] years of age to use the Website. By using the Website and by agreeing to these terms and conditions, you warrant and represent that you are at least 18 years of age.

The terms “usâ€, “weâ€, and “I†refer to the owner of the Website. The term “you†refers to the user or viewer of the website.

United States-specific Privacy Policies and Disclosures

If at any time you would like to unsubscribe from receiving future emails, you can email us at: [email protected] and we will promptly remove you from ALL correspondence.

EU-specific Privacy Policies and Disclosures

1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4    Our website incorporates privacy controls that affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.5    In this policy, “weâ€, “us†and “our†refer to Lauren Clayton. [ For more information about us, see Section 17.]

2. How we use your personal data

2.1    In Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics, Pinterest Analytics, Facebook Pixel, and various plugins. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

2.3    We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website 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.

2.4    We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details, and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website 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.

2.5    We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website 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.

2.6    We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data“). The inquiry data may be processed for the purposes of offering, marketing, and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.7    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.8    We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed [for the purposes of communicating with you and record-keeping. The legal basis for this processing is [our legitimate interests, namely the proper administration of our website and business and communications with users.

2.9    We may process behavior data (“behavior data“). This data may include links you clicked on within this site and any metadata associated with those links. The source of this data is a cookie placed by the action of clicking the link. This data may be processed for remarketing purposes. The legal basis for this processing is consent OR our legitimate interests, namely remarketing purposes and affiliate marketing purposes OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.10  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.12  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of 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.

2.13  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Automated decision-making

3.1    We will use your personal data for the purposes of automated decision-making in relation to remarketing campaigns.

3.2    This automated decision-making will involve remarketing campaigns on Facebook.

3.3    The significance and possible consequences of this automated decision-making are that you may be shown ads for our products and services on Facebook.

4. Providing your personal data to others

4.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company, and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3    We may disclose the name and email information to our suppliers or subcontractors insofar as reasonably necessary for email marketing and remarketing purposes.

4.4    We may disclose your inquiry data to one or more of those selected third-party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market, and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the inquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.5    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1    In Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    We and our other group companies have offices and facilities in the United States. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.3    The hosting facilities for our website are situated in the United States. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.4   Our subcontractors are situated in the United States. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.5    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1    In Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

(a) Usage data, profile data, account data, publication data, inquiry data, correspondence data, and behavior data will be retained for a minimum period of 10 days following October 14, 2021, and for a maximum period of 10 years following October 14, 2021.

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of notification data will be determined based on your choice to unsubscribe from our email newsletter provider.

6.5    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention 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.

7. Amendments

7.1    We may update this policy from time to time by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We will notify you of significant changes to this policy by email.

8. Your rights

8.1    In Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

8.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by submitting an email request to [email protected].

8.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; For compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims.

8.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

8.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

8.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13  You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.

9. Third-party websites

9.1    Our website includes hyperlinks to, and details of, third-party websites.

9.2    We have no control over and are not responsible for, the privacy policies and practices of third parties.

10. Personal data of children

10.1  Our website and services are targeted at persons over the age of 18.

10.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11. Updating information

11.1  Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. Acting as a data processor

12.1  In respect of usage data and behavior data, we do not act as a data controller; instead, we act as a data processor.

12.2  Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

13. About cookies

13.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.2  Cookies may be either “persistent†cookies or “session†cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

14. Cookies that we use

14.1  We use cookies for the following purposes:

(a)    authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: affiliate cookies from affiliate partner sites, Facebook Pixel);

(b)    advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: affiliate cookies from affiliate partner sites, Facebook Pixel);

(c)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: EU Cookie Consent Plugin).

15. Cookies used by our service providers

15.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

15.2  We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

15.3  We use Amazon Associates for affiliate marketing. This service uses cookies for tracking link clicks and purchases. You can view the privacy policy of this service provider at https://www.amazon.com/gp/help/customer/display.html?ie=UTF8&nodeId=468496 

16. Managing cookies

16.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

16.2  Blocking all cookies will have a negative impact upon the usability of many websites.

16.3  If you block cookies, you will not be able to use all the features on our website.

17. Our details

17.1  This website is owned and operated by Natasha Adamo

17.2  We are registered in California, United States of America as doing business as OPTIMAL PATHWAY, LLC. at 1223 Wilshire, P.O. 504 Santa Monica, CA 90401.

17.3  Our principal place of business is at 1223 Wilshire, P.O. 504 Santa Monica, CA 90401.

17.4  You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form;

(c)    by email, using the email address published on our website from time to time.