Privacy Policy

Global Intelligence Initiative LLC

1150 Nw 72nd Ave Tower I Ste 455 #5977
Miami, Florida 33126

By using our website, you agree to our privacy policy and terms & services. Please read these terms carefully before using our site or services.

EFFECTIVE DATE: September 2021

Section 1. OVERVIEW

Thank you for visiting our website. The terms “we,” “us” and “our” refer to, Global Intelligence Initiative Inc. The terms “website” or “site” refer to www.gii.media. The terms “user,” “users,” “you,” and “your” refer to website visitors and customers, whether personal or business entities, and include, but are not limited to, business entities’ agents, representatives, contractors, affiliates, and employees.

These Terms of Service (“Terms”) apply to all site users, customers, and other visitors of our website. By using our website and/or Services, you hereby agree to have read and acknowledged this Terms of Service and the Privacy Policy set forth herein (collectively referred to as “Agreement”), without modification.

The Privacy Policy (“Privacy Policy”) contained herein outlines how we may collect, use, and share information about you when using our website, together with products and services we offer from time to time on our website and social media pages, including, but not limited to, Instagram, SamCart, Zoom, LinkedIn, Teachable, Facebook, Pinterest, YouTube, Mighty Networks (collectively referred to as “Services”). This Policy describes both our and your legal rights and responsibilities with regards to information contained on and collected by our website, including information that identifies you, such as your name, location, contact information, e-mail address, search tendencies, and how you use our website (collectively referred to as “Personal Information”). We take seriously our responsibility to protect your personal information and privacy.

Section 2. TERM

This Agreement shall be effective immediately upon visiting, using or interacting with (collectively referred to as “using” or “visiting”) our website. By using our website, the user accepts to be bound by the terms included herein and shall remain effective so long as the user avails itself of the website’s Services.

We may change or amend this Agreement at any time. Any changes to this Agreement will be posted on our website and will be effective when published unless otherwise stated. If you use our website or Services after the effective date of any changes, then you agree to comply with the changes and the entire Agreement.

Section 3. APPLICABILITY

To use or access our website and Services, you must be eighteen years or older than the age of majority, and must have the ability to enter into this Agreement.

Section 4. USE FOR LAWFUL PURPOSES ONLY

All users and visitors must use this website and its Services for lawful purposes only. You hereby agree to use our website, content, products, and other Services for legitimate and non-commercial purposes only. You shall not transmit any material through our website which violates or infringes the rights of us or others, or material that is threatening, abusive, defamatory, profane, obscene, invasive, or which encourages criminal or illegal conduct or that would give rise to civil liability or otherwise violate any law.

Section 5. DISCLAIMERS, WARRANTIES, AND LIABILITY

A. EDUCATIONAL AND INFORMATIONAL PURPOSES ONLY

All of the information provided on our website and contained in our products, whether for purchase or not, is for educational and informational purposes only. Nothing on our website claims to guarantee accurate, complete, reliable or up-to-date information.

B. WARRANTIES & GUARANTEES

We strive to provide the most accurate information possible. However, we cannot ensure that our content is completely free from error or that it is timeless. As such, we do not give any warranty or other assurance as to the accuracy, completeness, timeliness, lack of errors, or fitness for particular purposes of any of the content or materials contained within and placed on our website, products, or other publications. To the maximum extent of the law, we provide our website and Services “as is” without any warranties, representations, or guarantees, whether express, implied, or otherwise.

C. EARNINGS & RESULTS

We make no guarantee of any kind regarding the potential income or results that can be generated through the use of our Services, products or website. From time to time, we may publish testimonials from clients - however, please keep in mind that past results are not an indication or promise of your results.

D. AFFILIATE PROGRAMS

We reserve the right to link to products or services for which we earn a commission, affiliate fee, or referral fee (all of which are interchangeable and mean the same thing for purposes of this Agreement). We will take reasonable measures to ensure that all affiliate links are labeled and disclaimed conspicuously.

E. LIMITATION OF LIABILITY

To the fullest extent permitted by applicable laws, we disclaim liability for any injuries, losses, or damages of whatever nature arising from the following, either directly, indirectly or consequentially: loss of use, loss of data, damage by Virus, loss or damage to property, claims of third-parties.

Section 6. SECURITY & INDEMNIFICATION

In order to maintain the security of your Personal Information, we have taken reasonable methods to prevent unauthorized access and maintain accuracy of all Personal Information collected by our website. Physical and technical methods of protection include limited numbers of internal personnel accessing your Personal Information, and password protecting documents or logs that contain Personal Information.

Transmission of information over the internet is not fully secure. As such, we cannot guarantee that any information you submit to us will be accessible to only us as the intended recipients. Any transmission is at your own risk. However, we do our best to protect your data and any information you provide. Nevertheless, if there is a security breach on behalf of an unauthorized party, you agree to indemnify us and hold us harmless for any and all claims against the unauthorized party.

We strive to prevent the introduction of malware, malicious code, and viruses to our website and our users (collectively referred to as “viruses”). However, due to the inherent nature of the internet, we are unable to guarantee or warrant that our websites, products, content or other Services are completely free from viruses. As such, we will not be liable for any damages or harm that is attributable to viruses that may arise after use of our website or Services. It is your responsibility to take reasonable measures to prevent the intrusion of viruses onto your hardware and software, and taking appropriate steps to ensure your computer and web browser are not exposed to the risk of interference or damage from viruses.

Your use of our website, products and Services is completely voluntary. As such, you shall indemnify us and hold us and our agents and affiliates harmless for any damages or injury that may arise from your use of our website, products and Services, which include, but are not limited to, issues regarding the confidentiality and security of your Personal Information.

Section 7. ACCEPTANCE & SCOPE OF PRIVACY POLICY

This Privacy Policy is part of our Terms of Services, which address your access, exchange of information, and use of our Services. The Privacy Policy (outlined in this Section and Sections 1-4, 6-11, 13, 16 and 17), is incorporated herein. By using our website and Services, you hereby agree to all of the terms set forth in our Terms of Service and Privacy Policy. If you do not agree with our Terms of Service or Privacy Policy, then please do not use our website or Services.

This Privacy Policy applies to your Personal Information that is collected by us on our website through when you elect to use our Services. For more information about how we collect and use your information, see Sections 8 and 9 below.

This Privacy Policy does not cover the collection and/or use of your personal information by third-party programs or websites, such as search engines (i.e Google), commerce platforms and plug ins (i.e PayPal, Venmo, Teachable, Kajabi), website hosts (squarespace, kajabi, teachable), email marketing programs, video or messenger applications (Zoom, Slack, Mighty Networks), teaching or webinar platforms (i.e Kajabi, Teachable, Instagram, Zoom) or social media platforms. The collection and use of data and information by third-party platforms and programs, such as those described above, are governed by each third-party’s respective privacy policy. However, you should not assume that third-parties have a privacy policy that is equivalent or similar to ours. As such, we are not liable or responsible under any circumstances for the collection and use of your personal information by third-parties or the third-parties’ compliance with their respective privacy policies.

By accepting our Privacy Policy, you hereby acknowledge that you are above the age of consent and majority in your jurisdiction. Minors should not use this platform and, as such, we do not knowingly or intentionally collect, share, or use Personal Information from minors.

Section 8. INFORMATION COLLECTED

A. “PERSONAL INFORMATION” THAT IS SUBJECT TO THESE TERMS AND PRIVACY POLICY INCLUDE, BUT ARE NOT LIMITED TO:

Information in exchange for products or services - From time to time, we ask for personal information, such as names, e-mail addresses, phone numbers, credit card numbers, account information and/or billing addresses in an exchange for our product, content, or Services.

Analytics - This website collects data, such as visitor location and times, in order to help us analyze user data and better serve our users. From time to time, our website may collect data such as cookies, pixel tags, clickstreams, and other modern technology to collect information such as browser type, web pages viewed, links clicked, and other actions you may take either on our website or via social media accounts and e-mails associated with us. This information may be used from time to time to help us personalize your experience or for security purposes. Cookies are pieces of data from a web server to your web browser and saved on your hard drive. Cookies do not contain personally identifiable information, such as your name or contact information. You may adjust your browser settings with regards to the collection of internet cookies - for example, you may delete, block and/or refuse cookies, or you may elect to be notified before cookies are placed.

Log Files - Modern websites often collect user data in the form of log files. This is a modern way to log when and from where a user enters our website. This data may include information such as internet protocol (IP) addresses, browsers, date and time stamps, referral links through which you entered our website, demographic information, and the number of clicks a user makes on our site. This information is separate from Personal Information described above, and does not include information that is personal to you on an individual level. This information is used to track general traffic flow and usage of our website, in addition to other trends and statistics such as the number of visitors to a certain page on our website.

Transaction Information - When you download or purchase a product from our website, certain information may be collected, such as the date of the purchase and product details. This information is collected and used for internal purposes only, in order to enhance the general user experience. If you purchase one of our products, certain data is required to fulfill your request, such as credit card numbers/expirations/security codes, billing information and addresses, zip codes, and names, which will be processed through a third-party payment program. This information will not be shared intentionally with any party other than the third-party programs responsible for processing your payment and procuring payment to us.

Third-Party Information - From time to time, we may receive information from third party plug ins or programs such as paypal, kajabi or teachable….Google, Squarespace, or through social media platforms.

B. INFORMATION MAY BE COLLECTED IN ONE OR MORE OF THE FOLLOWING WAYS:

Provided by you, the user - Our website may ask you to input Personal Information from time to time. For instance, we request your e-mail address and name to send you a protected piece of content or may ask for your e-mail address when you have a question relating to customer service or consultations.

Collected from internet browsers or devices - From time to time, data is collected and sent to us automatically by your web browser or device. Information collected in this category tends to include your IP address, links clicked, pages visited, and time stamps of visits. This information tends not to be personally identifiable.

Cookies, pixels, web beacons, widgets, and other modern technologies - This site uses cookies to collect information to monitor and aggregate web traffic to our site. This site may also use web beacons, pixels, and social media widgets to help us understand browsing activity and traffic patterns. This information helps us improve our website, Services, and the user’s online experience. For example, social media widgets may be placed on our website by third-party social media platforms to allow you to interact with our social media accounts. These modern technologies may also collect browsing data, although the collection and use of data amongst these third-parties is subject to their control and respective privacy policies. Please see Section 10 below for information as to how you can opt out or limit how we use cookies.

Section 9. INFORMATION USED

A. BY USING OUR WEBSITE, YOU HEREBY AGREE THAT ANY AND ALL INFORMATION COLLECTED IN SECTION 8 HERETO MAY BE USED FOR THE FOLLOWING PURPOSES:

To provide content, products, and other Services to you;
To process and fulfill any purchases or orders, which may include sending e-mails to you;
To communicate with you, such as via e-mail, including promotional e-mails, newsletters, and product attachments;
To provide customer service and manage individual accounts;
To provide a you with a personalized online experience;
To grant you access to certain content and services online;
To educate us on our user’s tendencies and preferences;
To fulfill a contract we have with you;
To optimize our website and our users’ experience;
To prevent, mitigate, and investigate security breaches;
To verify or authenticate information;
To respond to lawful requests from government authorities, if applicable;
To resolve disputes with users;
To prevent fraud or security issues;
To fulfill or enforce our agreements with third-parties;
To enforce our Terms of Use.
To protect our legitimate business interests, which include but are not limited to: i) providing or administering Services to you and our users; ii) maintaining records; iii) analyzing data for business purposes and quality assurance; iv) communicating with you regarding the administration of Services and our obligations associated therewith; v) legal purposes, such as in dispute resolution, litigation, investigations, or regulatory purposes.

B. THE PERSONAL INFORMATION COLLECTED AND USED MAY BE SHARED WITH CERTAIN THIRD-PARTIES. PERSONAL INFORMATION MAY BE SHARED IN THE FOLLOWING WAYS:

Service providers - Personal Information may be shared with third-party programs, platforms, and providers in exchange for data, analytics, reports, or confidentiality agreements. Third-party providers include, but are not limited to, the following: website hosts, e-commerce platforms, payment providers and payment processors, website plugins, e-mail servicing programs, marketing consultants, and brand advisors. These third-party providers shall only collect, use, maintain and share your information to the extent that doing so furthers the services they provide to us. Any use beyond that scope shall be deemed an unauthorized use, of which you hereby agree to indemnify us.

Social sharing - Personal Information may be shared by you if you elect to post content on our website, social media pages, or accounts. Your Personal Information may also be disclosed when you elect to connect your social media accounts to your accounts on our website or e-commerce page, which is then subject to the privacy policy of the respective social media platform.

Asset Sale or Transfer - Personal Information may also be shared in the event of a merger, acquisition, asset sale, or other transfer of our business and assets.

Legal and/or Regulatory Disclosures - Personal Information may also be shared if necessary to further a legal, regulatory, audit, or professional investigation.

C. THE PERSONAL INFORMATION THAT IS COLLECTED WILL BE STORED IN A COMMERCIALLY REASONABLE MANNER FOR AS LONG AS IS NECESSARY TO PROTECT OUR LEGITIMATE BUSINESS INTERESTS, AND TO COMPLY WITH APPLICABLE LAW. WE RESERVE THE RIGHT TO COLLECT AND STORE YOUR PERSONAL INFORMATION TO THE EXTENT THAT IT IS NOT PROHIBITED BY LAW.

D. WE DO NOT SELL OR LICENSE YOUR PERSONAL INFORMATION TO THIRD-PARTIES FOR THEIR OWN MARKETING OR COMMERCIAL PURPOSES WITHOUT YOUR CONSENT.

Section 10. CHOICE AND OPT-OUT

Cookies & Behavioral Based Advertising - We may work with third-parties, such as Google and Facebook, for marketing, advertising and other legitimate business purposes. For information as to how you can opt-out of some of these advertising services, be sure to change your internet browser’s settings to block cookies or ask permission before collecting cookies.

E-mail Marketing - We may, from time to time, require your e-mail address and other Personal Information to use our Services. If you do not want us to contact you via e-mail for promotional purposes, account management, updates, or product information, then you can elect not to share your e-mail address with us (although it may nevertheless be necessary to utilize a certain Service). At any time, you may manage your e-mail subscription preferences by contacting us at hello@gii.media at the link on the bottom of each e-mail sent by us.

Google Analytics - In order to opt out of Google Analytics, you may visit: https://tools.google.com/dlpage/gaoptout.

European Union - Residents of the European Union may have the following rights with respect to the collection and use of their Personal Information: i) right to review, verify, correct, and request erasure of your Personal Information that we collect and store; ii) limit, restrict, or object to the use of your Personal Information under certain circumstances; iii) the right to request the transfer of your Personal Information to another party under certain circumstances. For more information regarding your rights to your Personal Information in the European Union, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

California - Residents of California who are users of our site may request certain information regarding the disclosure of their Personal Information to third-parties for marketing purposes. All requests of this nature should be specific and addressed via e-mail to hello@gii.media Users may also utilize a preference on their internet browser called Do Not Track. However, we may not respond to Do Not Track settings. For more information about California Do Not Track and your rights as a California resident with respect to your Personal Information, please visit: www.allaboutdnt.org.

Section 11. GOVERNING LAW & VENUE

Global Intelligence Initiative Inc is located in Florida and is subject to the applicable laws governing the country of United States of America.

Section 12. INTELLECTUAL PROPERTY & STOCK PHOTOGRAPHY

Stock Photography - This website may use free stock photography as part of its design. All stock images used have an irrevocable, non-exclusive copyright license to download, copy, distribute, use and modify the photos for free, including for commercial purposes. Use of said stock photography is permissible under applicable laws without permission from the photographer or attributing the work to the photographer.

Intellectual Property - This website, content and products contain intellectual property owned by us. and by third-parties that license some intellectual property to us. This Agreement is intellectual property owned by us. Other examples of intellectual property found on our website and within our products and Services include, but are not limited to: trademarks, service marks, layout, logos, business name, design, text, written copy, certain images, podcast recordings, videos, audio files, and all of our paid products (collectively referred to as “Intellectual Property”). You shall not copy, publish, transmit, transfer, sell, create derivative works from, reproduce, or in any way exploit any of the Intellectual Property owned by us and the third-parties described within this Section in either whole or part without prior written consent.

Section 13. MISCELLANEOUS

Amendments - We reserve the right to amend this Agreement from time to time. You are bound by any changes made after the publication of the changes on our website. We will take reasonable efforts to notify you of any changes that are made.

Headings & Severability - Headings are included for convenience purposes only and shall not affect the construction of this Agreement. If any portion of this Agreement is held to be unenforceable, it shall not affect the remaining portions of the Agreement, which shall remain in full effect. If any portion of this Agreement is held to be unenforceable, then the unenforceable portion shall be construed in compliance with applicable law in a light most favorable to the original intentions of the parties. If the unenforceable portion of the Agreement is found by a competent court of this jurisdiction to be contrary to law, then it shall be changed and interpreted to best reflect the original intentions of the parties, and all other provisions shall remain in full force and effect.

Entire Agreement - This Agreement reflects the entire agreement between the parties. This Agreement trumps any other existing negotiations, communications or Agreements between the parties, whether written, oral, or electronic, and is the full extent of the Agreement between the parties.

Section 14. SPECIFIC PRODUCT TERMS OF USE [ RESERVED]

Section 15. GENERAL TERMS OF USE

Refund Policy - Due to the nature of the products and Services provided, and the electronic transmission of same, you hereby agree and acknowledge that all sales are final. You agree and acknowledge that your purchase of any product or Service is non-refundable, under any circumstances.

Limited License - You acknowledge that any and all products or Services that you download are for your own personal and internal business use. You shall not copy, reproduce, transmit, modify, edit, create derivative works from, alter, sell, or share with others any products or Services that you purchase or download from our website, without prior written consent or unless provided otherwise. We grant you a limited, personal, non-exclusive and non-transferable license to use the Products for your personal and internal business use.

Section 16. UPDATES

Global Intelligence Initiative, gii.media, gii.academy, does not accept any responsibility for any errors on this website (including omissions or inaccurate material). All content written on this site is protected by copyright and cannot be reproduced without the express permission of Global Intelligence Initiative. If it is found that material is being reproduced, without the permission of Global Intelligence Initiative, Global Intelligence Initiative, will prosecute the parties involved to the full extent of the law. The above clause does not extend to any RSS feeds that Global Intelligence Initiative provides or to cases where explicit Global Intelligence Initiative permission was granted. If you are unhappy with any of the terms as outlined above your sole and exclusive remedy is to discontinue using Global Intelligence Initiative.

Privacy is of utmost importance at Global Intelligence Initiative. We recognize the significance of protecting information which is stored on our servers or network or is intended to be stored on our servers or network and which relates to an individual. This Privacy Policy is designed to address regulatory requirements of the jurisdictions in which Global Intelligence Initiative offers its Services, including the General Data Protection Regulation (“GDPR”), as enacted by the European Commission and the Florida Consumer Privacy Act (“FIPA”).

In this Privacy Policy, the terms “Service” and “Services” have the same meaning as described in the Terms and Conditions. This Privacy Notice applies to all processing of Personal Data on the website Global Intelligence Initiative and all other Global Intelligence Initiative sites on which it appears (the “Sites”). If you do not agree with this Privacy Policy, in general, or any part of it, you should not use the Sites or Services. This Privacy Policy is periodically reviewed to ensure that any new obligations and changes to our business model are taken into consideration.

We may amend this Privacy Policy at any time by posting an amended version on our website. In this privacy policy, we will tell you:

• ● What Personal Data we collect from you and how we collect it;

• ● On what legal basis we collect your Personal Data;

• ● For what purpose we collect your Personal Data;

• ● How long we store it for;

• ● Who do we share your Personal Data with;

• ● Whether we intend to transfer it to another country;

• ● What are your rights with respect to your Personal Data; and

• ● Children’s Privacy; and

• ● Changes to this Privacy Policy.

1. What data do we collect about you and how do we collect it?

We collect your Personal Data through a variety of methods: either you provide it to us directly, we collect it from external sources, or we collect it by using automated means.Information you may provide to us: You may give us information about you by filling in forms on our Sites or through our app or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the Services and when you report a problem with the Sites or with our app. Information we collect about you: Regarding each of your visits to our Sites or our app we automatically collect the following information:

• ● Login Information: We log technical information about your use of the Services, including the type of browser and version you use, the last access time of your visit, the Internet Protocol (IP) address used to create your account and the most recent IP address used to access your account. Device Information: We collect information about the device you use to access your account, including the hardware model, operating system and version, and unique device identifiers, but this information is anonymized and not tied to any person. • Information We Collect Required by Law, Rule, or Regulation: Depending on the Service, we may collect information from you in order to meet regulatory obligations around know-your-customer (“KYC”) and the information that we collect from you includes the following: External Sources: We also receive information from other sources and combine that with the information we collect through our Services.

For instance:● We use “cookies” from time to time to help personalize your online experience with us. A cookie is a small text file that is stored on your computer to help us make your visit to our Sites more “user-friendly.” Please see our Cookie Policy for more details about the cookies we use. Cookies provide us with information about your use of the Sites that can help us improve the Sites and your experience with it. We will process Personal Data collected through cookies in accordance with this Privacy. Types of personal data collected: This could include a list of the types of personal data, such as name, address, email, phone number, etc. • If you have set your browser to alert you before accepting cookies, you should receive an alert message with each cookie. You may refuse cookies by turning them off in your browser, however, you should be aware that our Sites, like most other popular sites, may not work well with cookies disabled.

• ● We use third-party services that may be co-branded as Global Intelligence Initiative but will do so with clear notice. Any third-party services may collect information as determined by their own privacy policies.

• ● Advertising or analytics providers may provide us with anonymized information about you, including but not limited to, how you found our website. •

2. On what basis do we collect your data?

We only use your Personal Data where we have a legal basis to do so: Consent. For some processing activities, we require your prior consent. This applies for example to some of our direct marketing activities which fall under the scope of the GDPR. You will always be prompted to take clear, affirmative action so that we can ensure that you agree with the processing of your Personal Data. This action may, for example, take the form of a checkbox. If you have given us your consent for processing operations, you may always change your mind, and withdraw your consent at any time and easily; all you need to do is to send us an email at the following address hello@gii.academy

Legitimate interest. In most cases where we process Personal Data in the context of our Services, we rely on our legitimate interests in conducting our normal business as a legal basis for such processing. Our legitimate interests are to identify or prevent fraud, to enhance the security of our network and information systems, or to carry out processing operations for statistical purposes. We will use legitimate interest only when we have carried out an assessment on the impact that this processing may have on you and concluded that the processing does not unduly infringe your rights and freedoms. For example, we do not use this justification if we process sensitive data, or when the processing would be unexpected for you, or if we consider it to be too intrusive.

3. For what purposes do we collect your data?

We collect your Personal Data to: Provide our Services (including customer support); Troubleshoot problems; Communicate with you about our Services and business and to inform you of matters that are important for your account and/or use of the Sites. We also use your Personal Data to respond to any questions, comments or requests you filed with us; Comply with applicable laws and regulations; Establish, exercise and defend legal claims; Monitor and report compliance issues; Customize, measure, and improve our business, the Services, and the content and layout of our – Sites and apps (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services, websites and apps; ensuring the security of our networks and information systems; performing accounting, auditing, invoicing, reconciliation and collection activities; and improving and maintaining the quality of our customer services); Perform data analysis; Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences, and measure the effectiveness of it. To approach you via email for marketing purposes, we request your consent, unless it is not required by law. You always have the option to unsubscribe from our mailings, e.g., via the unsubscribe link in our newsletter; Perform risk management, including comparing information for accuracy and verify it with third parties and protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities; and Enforce our contractual terms.

4. How long do we keep your data?

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.

• ● Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.

• ● Content that you post on our Sites such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).

• ● Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from expiry of the cookie. When Personal Data is no longer necessary for the purpose for which it was collected, we will remove any details that identifies you or we will securely destroy the records, where permissible. However, we may need to maintain records for a significant period of time (after you cease using a particular Service) as mandated by regulation.

5. Who do we share your personal data with?

We may share your information with selected recipients to perform functions required to provide certain Services to you. All such third parties will be contractually bound to protect data in compliance with our Privacy Policy. The categories of recipients include:

• ● Other Global Intelligence Initiative entities, including to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications;

• ● Service providers who help with our business operations and to deliver our Services, such as:

• ■ Cloud service providers providing cloud infrastructure;

• ■ Providers of ID verification solutions and other due diligence solutions (such as KYC and anti-money laundering);

• ■ Providers of website analytics;

• ■ Providers of customer service solutions; and

• ■ Providers of marketing automation platforms.

• ● Law enforcement, government officials, regulatory agencies, our banks, and other third parties pursuant to a subpoena, court order or other legal process or requirement if applicable to Global Intelligence Initaitive; or when we believe, in our sole discretion, that the disclosure of data is necessary to report suspected illegal or fraudulent activity or to investigate violations of our Terms and Conditions. We also may share Personal Data with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Global Intelligence Initiative assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by Global Intelligence Initiative is among the assets transferred.

6. Is your data transferred outside of the European Union?

As we are located outside of the European Union, we will ensure that any entity, whether our processor or affiliate that transfers Personal Data to us from the EU employs appropriate safeguards. If your Personal Data is transferred to us from the European Economic Area by our service providers (i.e., Data Processors who are engaged on our behalf) and business partners, we will ensure that the transfer is lawful. 7. What are your rights? Under the GDPR and relevant implementation acts, individuals have statutory rights related to their Personal Data. Please note that rights are not absolute and may be subject to conditions.One key right is the Right to object. You have the right to object to processing of your Personal Data where we are relying on legitimate interests as our legal basis (see above). Under certain circumstances, we may have compelling legitimate grounds that allow us to continue processing your Personal Data. Insofar as the processing of your Personal Data takes place for direct marketing purposes, including profiling for direct marketing, we will always honor your request. Other rights are as follows:

• ● Right to withdraw consent. Insofar as our processing of your Personal Data is based on your consent (see above), you have the right to withdraw consent at any time.

• ● Right of access. You have the right to request access to your Personal Data.

• ● Right to rectification. You have the right to request rectification of the Personal Data that we hold about you.

• ● Right to erasure. You have the right to request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data in certain circumstances.

• ● Right to restriction. You have the right to request restriction of processing of your Personal Data.

• ● Right to data portability. In some cases, you have the right to request to transfer your Personal Data to you or to a third party of your choice. The exercise of the aforementioned rights is free of charge and can be carried out by submitting an inquiry by contacting us at hello@giii.academy

Before responding to your request, we will verify your identity and / or ask you to provide us with more information to respond to your request, if we have any doubts about your identity. We will do our best to respond to your request within one month, unless your request is particularly complex (for example if your request concerns a large amount of sensitive data). In such a case, we will inform you of the need to extend this response time by two additional months.

8. What about children’s privacy?

Global Intelligence Initiative does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us at hello@gii.academy. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

9. What happens if we make changes to this policy?

We may update this policy to reflect changes to our information practices, but we will not reduce your rights under this Privacy Policy without your express consent. We will post any changes to this page and, if the changes are significant, we will provide a more prominent notice. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices and to contact us if you have any questions or concerns.

10. California Consumer Privacy Act Addendum. At Global Intelligence Initiative , we take our responsibilities under the California Consumer Privacy Act (“CCPA”) seriously. If you are a California resident, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA.For such residents, the provisions of this CCPA Addendum prevail over any conflicting provisions in our Global Intelligence Initiative Privacy Notice.

1. California Personal Information We Collect.

We have collected the following categories of California Personal Information within the last 12 months: CATEGORY EXAMPLES Identifiers E-mail address, unique personal identifier, online identifier, Internet Protocol address, country of residence, or other similar identifiers. Information under the California Customer Records statute “Personal Information” described in subdivision (e) of Section 1798.80 (California Customer Records statute). This means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, social security number, address, telephone number, passport number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or any other financial information. Commercial information Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies on our site Internet or other similar network activity Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement Geolocation data Geolocation data Inferences drawn from other personal information Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes For each of these categories, we obtain California Personal Information from a variety of sources. These sources include: yourself, with respect to both online and offline interactions you may have with us or our service providers; other entities with whom you transact; others with whom you maintain relationships who may deal with us on your behalf; the devices you use to access our websites, mobile applications, and online services; identity verification and fraud prevention services; marketing and analytics providers; public databases; social media platforms; and others consistent with this CCPA Addendum. For more information, please see the “For what purposes do we collect your data?” section of our Privacy Notice. For each of these categories, we share Personal Information with a variety of third parties. These third parties include: other Global Intelligence Initiative entities; service providers; marketing and advertising providers; analytics providers; law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other applicable legal process or requirement; and merchants in cases of suspected fraud or in connection with an ongoing investigation.

2. Sale and disclosure of California Personal Information.

Within the last 12 months, within the meaning of “sale” under the California Consumer Privacy Act, we have disclosed California Personal Information identified in the above categories for business purposes. This includes the use of cookies and pixels on our website, including those placed by third parties. You can configure your browser to prevent the placement of cookies when using our site. To learn more about cookies, please see our Cookie Policy or your browser help documentation for more information. To learn more about the categories of third parties with whom we share such information, please see the “Who do we share your Personal Data with?” section of our Privacy Notice.

3. Use of California Personal Information.

For each of the above categories, we use the California Personal Information we collect for the business purposes disclosed within this CCPA Addendum. Please note that the business purposes for which we may use your information include:

• ● Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;

• ● Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;

• ● Debugging to identify and repair errors in our systems;

• ● Short-term, transient use including contextual customization of ads or website;

• ● Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;

• ● Conducting internal research to develop and demonstrate technology; and

• ● Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide. We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.

4. Your California Rights.

If you are a California resident, you have certain rights related to your California Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. If you wish to submit a request under the CCPA, please do so by writing to hello@gii.academy. As required under applicable law, we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information to verify your identity in response to exercising requests of the above type, including name and account information. We may limit our response to your exercise of the below rights as permitted under applicable law.

4.1. Right to Access/Know. You have the right to request that we disclose to you:

• ● the categories of California Personal Information we have collected about you

• ● the categories of sources from which the California Personal Information is collected;

• ● our business or commercial purpose for collecting or selling California Personal Information; • ● the categories of third parties with whom we share California Personal Information; and

• ● the specific pieces of information we have collected about you. To the extent that we sell your California Personal Information within the meaning of the California Consumer Privacy Act or disclose such information for a business purpose, you may request that we disclose to you:

• ● the categories of California Personal Information that we have collected about you;

• ● the categories of California Personal Information about you that we have sold within the meaning of the California Consumer Privacy Act and the categories of third parties to whom the California Personal Information was sold, by category or categories of personal information for each third party to whom the California personal information was sold; and

• ● the categories of California Personal Information about you that we disclosed for a business purpose.

4.2. Right to Delete.

You have the right to request that we delete California Personal Information about you which we have collected from you.

4.3. Right to Opt-Out and Right to Opt-In.

You have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”) by managing your cookie preferences by contacting us at hello@gii.academy.

4.4. Non-Discrimination.

Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:

• ● Denying you goods or services;

• ● Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• ● Providing you a different level or quality of goods or services; or

• ● Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

5. Changes to this Notice. We may amend this Notice at any time by posting a revised version on our website. The revised version will be effective at the time we post it. You are responsible for periodically reviewing this Notice.

6. Contact Information .

You may contact us with questions or concerns about our privacy policies or practices at hello@gii.academy

Section 17. CONTACT

You may contact us at any time with questions or concerns regarding our Terms of Use and Privacy Policy. To do so, please e-mail us at hello@gii.media

PRIVACY POLICY

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