Aspire To Retire Rich
Privacy Policy and Cookie Policy
August 16th, 2018

Background:
Aspire To Retire Rich respects and values the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your
rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site.

Please read this Privacy Policy carefully and ensure that you understand it.

Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;

[“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when
you use certain features of Our Site. Details of the Cookies used
by Our Site are set out in section 12, below;]

Our Site” means this website, https://www.aspiretoretirerich.com/
[“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and 2018]

“We/Us/Our” means Aspire To Retire Rich, P.O. Box 996 Nederland, CO 80466

Information About Us
Our Site, https://www.aspiretoretirerich.com/ is [owned and] operated by Aspire To Retire Rich,
Our data protection officer is Megan McAvoy Matté who can be contacted at
megan@aspiretoretirerich.com


Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

What Data Do We Collect?
Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account or Opt-In. Depending upon your use of Our Site,
We may collect some or all of the following data:
[Name;]
[gender;]
[business/company name]
[job title;]
[profession;]
[contact information such as email addresses and telephone numbers;]
[demographic information such as post code, preferences and interests;]
[financial information such as credit / debit card numbers;]
[IP address (automatically collected);]
[web browser type and version (automatically collected);]
[operating system (automatically collected);]
[a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to
(automatically collected);]

How Do We Use Your Data?
All personal data is stored securely in accordance with the EU General Data Protection Regulation
(Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
We use your data to provide the best possible products and services to you. This includes:
[Providing and managing your Account;]
[Providing and managing your access to Our Site;]
[Personalizing and tailoring your experience on Our Site;]
[Supplying Our [products and] services to you;]
[Personalizing and tailoring Our [products and] services for you;]
[Responding to communications from you;]
[Supplying you with email: newsletters, alerts etc. that you have subscribed to (you may
unsubscribe or opt-out at any time by Unsubscribing;]
[Market research;]

[Analyzing your use of Our Site [and gathering feedback] to enable Us to continually improve Our
Site and your user experience;]
[Add further uses as required.]
In some cases, the collection of data may be a statutory or contractual requirement, and We will be
limited in the [products and] services We can provide you without your consent for Us to be able to
use such data.
With your permission and/or where permitted by law, We may also use your data for marketing
purposes which may include contacting you by [email] AND/OR [telephone] AND/OR [text message]
AND/OR [post] with information, news and offers on Our [products] AND/OR [services]. We will
not, however, send you any unsolicited marketing or spam and will take all reasonable steps to
ensure that We fully protect your rights and comply with Our obligations under the GDPR and the
Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011
and 2015.
Advertisers whose content appears on Our Site may engage in what is known as “behavioral
advertising” – advertising which is tailored to your preferences, based on your activity. Your activity
is monitored using Cookies, as detailed below in section 12. You can control and limit your data used
in this way by adjusting your web browser’s privacy settings. Please note that We do not control the
activities of such advertisers, nor the information they collect and use. Limiting the use of your data
in this way will not remove the advertising, but it will make it less relevant to your interests and
activities on Our Site.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently,
without adversely affecting your rights. We will only process your personal data if at least one of the
following basis applies:
a) you have given consent to the processing of your personal data for one or more
specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or
in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are
subject;
d) processing is necessary to protect the vital interests of you or of another natural
person;
e) processing is necessary for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the controller; and/or
a) processing is necessary for the purposes of the legitimate interests pursued by us or by a
third party, except where such interests are overridden by the fundamental rights and
freedoms of the data subject which require protection of personal data, in particular where
the data subject is a child.

How and Where Do We Store Your Data?
We only keep your data for as long as We need to in order to use it as described above in section 5,
and/or for as long as We have your permission to keep it. In any event, We will conduct an annual
review to ascertain whether we need to keep your data. Your data will be deleted if we no longer
need it in accordance with the terms of our Data Retention Policy.
Some or all of your data may be stored or transferred outside of the European Economic Area (“the
EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do
store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is
treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may
include, but not be limited to, the use of legally binding contractual terms between Us and any
third parties We engage and the use of the EU-approved Model Contractual Arrangements. [If We
intend at any time to transfer any of your data outside the EEA, We will always obtain your
consent beforehand and we have put in place safeguards to protect your data:
Data security is of great importance to Us, and to protect your data We have put in place suitable
physical, electronic and managerial procedures to safeguard and secure data collected through Our
Site.
We take steps to make sure your data is secure
Notwithstanding the security measures that We take, it is important to remember that the
transmission of data via the internet may not be completely secure and that you are advised to take
suitable precautions when transmitting to Us data via the internet.

1. Do We Share Your Data?
2. We may contract with third parties to supply [products and] services to you on Our
behalf. These may include payment processing, delivery of goods, search engine
facilities, advertising and marketing. In some cases, the third parties may require
access to some or all of your data. Where any of your data is required for such a
purpose, We will take all reasonable steps to ensure that your data will be handled
safely, securely, and in accordance with your rights, Our obligations, and the
obligations of the third party under the law. We currently contract with:
1. We may compile statistics about the use of Our Site including data on traffic, usage
patterns, user numbers, sales and other information. All such data will be
anonymized and will not include any personally identifying information. We may
from time to time share such data with third parties such as prospective investors,
affiliates, partners and advertisers. Data will only be shared and used within the
bounds of the law.
2. In certain circumstances We may be legally required to share certain data held by Us,
which may include your personal information, for example, where We are involved in
legal proceedings, where We are complying with the requirements of legislation, a
court order, or a governmental authority. We do not require any further consent
from you in order to share your data in such circumstances and will comply as
required with any legally binding request that is made of Us.

2. What Happens If Our Business Changes Hands?
2. We may, from time to time, expand or reduce Our business and this may involve the
sale and/or the transfer of control of all or part of Our business. Data provided by
users will, where it is relevant to any part of Our business so transferred, be
transferred along with that part and the new owner or newly controlling party will,
under the terms of this Privacy Policy, be permitted to use the data for the purposes
for which it was originally collected by Us.
1. In the event that any of your data is to be transferred in such a manner, we will
contact you and inform you about it.

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3. How Can You Control Your Data?
2. When you submit information via Our Site, you may be given options to restrict Our
use of your data. We aim to give you strong controls on Our use of your data
(including the ability to opt-out of receiving emails from Us which you may do by
unsubscribing using the links provided in Our emails or contact us directly.

4. Your Right to Withhold Information and Your Right to Withdraw Information After
You Have Given it
2. You may restrict your internet browser’s use of Cookies. For more information, see
section 12
1. You may withdraw your consent for Us to use your personal data as set out in section
in 5 at any time by contacting Us using the details set out in section 15, and We will
delete Your data from Our systems. However, you acknowledge this may limit Our
ability to provide the best possible service to you.

1. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at megan@aspiretoretirerich.com

2. What Cookies Do We Use and What For?
2. Our Site may place and access certain first party Cookies on your computer or device.
First party Cookies are those placed directly by Us and are used only by Us. We use
Cookies to facilitate and improve your experience of Our Site and to provide and
improve Our services/products. For more details, please refer to section 5, above,
and to section 12.6 below. We have carefully chosen these Cookies and have taken
steps to ensure that your privacy is protected and respected at all times.
1. By using Our Site you may also receive certain third party Cookies on your computer
or device. Third party Cookies are those placed by websites, services, and/or parties
other than Us. We use third party Cookies on Our Site for marketing, and
understanding our target audience . For more details, please refer to section 5,
above, and to section 12.6 below. These Cookies are not integral to the functioning
of Our Site.
2. All Cookies used by and on Our Site are used in accordance with current English and
EU Cookie Law.
3. Certain features of Our Site depend on Cookies to function. EU Cookie Law deems
these Cookies to be “strictly necessary”. These Cookies are shown below in section
12.6. Your consent will not be sought to place these Cookies. You may still block
these Cookies by changing your internet browser’s settings as detailed below in
section 12.10, but please be aware that Our Site may not work as intended if you
do so. We have taken great care to ensure that your privacy is not at risk by
allowing them.
4. The following first party Cookies may be placed on your computer or device:

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Facebook Pixel - Retargeting and statics
Google Analytic Pixel - Statics
5. Our Site uses analytics services provided by Google. Website analytics refers to a set
of tools used to collect and analyze usage statistics, enabling Us to better understand
how people use Our Site. However whilst Our use of them does not pose any risk to
your privacy or your safe use of Our Site, it does enable Us to continually improve
Our Site, making it a better and more useful experience for you.
6. The analytics service(s) used by Our Site use(s) the following Cookies:
7. You can choose to enable or disable Cookies in your internet browser. Most internet
browsers also enable you to choose whether you wish to disable all cookies or only
third party cookies. By default, most internet browsers accept Cookies but this can be
changed. For further details, please consult the help menu in your internet browser
or the documentation that came with your device.
8. You can choose to delete Cookies at any time however you may lose any information
that enables you to access Our Site more quickly and efficiently including, but not
limited to, login and personalization settings.
9. It is recommended that you keep your internet browser and operating system up-to-
date and that you consult the help and guidance provided by the developer of your
internet browser and manufacturer of your computer or device if you are unsure
about adjusting your privacy settings.

OR

13. Cookies
Our Site may place and access certain first party Cookies on your computer or device. First
party Cookies are those placed directly by Us and are used only by Us. We use Cookies to
facilitate and improve your experience of Our Site and to provide and improve Our [products
and] services. By using Our Site you may also receive certain third party Cookies on your
computer or device. Third party Cookies are those placed by websites, services, and/or
parties other than Us. We use third party Cookies on Our Site for [Insert description of use of
third party cookies, e.g. advertising services]. In addition, Our Site uses analytics services
provided by [Insert name of analytics service provider(s)], which also use Cookies. Website
analytics refers to a set of tools used to collect and analyze usage statistics, enabling Us to
better understand how people use Our Site.
Summary of Your Rights under GDPR
Under the GDPR, you have:
the right to request access to, deletion of or correction of, your personal data held by Us;
the right to complain to a supervisory authority;
be informed of what data processing is taking place;
the right to restrict processing;
the right to data portability;
object to processing of your personal data;

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rights with respect to automated decision-making and profiling (see section 14 below).
To enforce any of the foregoing rights or if you have any other questions about Our Site or this
Privacy Policy, please contact Us using the details set out in section 15 below.
Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated decision-making and
those decisions have a legal (or similarly significant effect) on You, You have the right to
challenge to such decisions under GDPR, requesting human intervention, expressing their
own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
The decision is necessary for the entry into, or performance of, a contract between the You and Us;
The decision is authorized by law; or
You have given you explicit consent.

Where We use your personal data for profiling purposes, the following shall apply:
Clear information explaining the profiling will be provided, including its significance and the likely
consequences;
Appropriate mathematical or statistical procedures will be used;
Technical and organizational measures necessary to minimize the risk of errors and to enable such
errors to be easily corrected shall be implemented; and
All personal data processed for profiling purposes shall be secured in order to prevent discriminatory
effects arising out of profiling.
Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at
megan@aspiretoretirerich.com, or by post at P.O. Box 996 Nederland, CO 80466. Please
ensure that your query is clear, particularly if it is a request for information about the data
We hold about you (as under section 11, above).
Changes to Our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may
be required by law. Any changes will be immediately posted on Our Site and you will be
deemed to have accepted the terms of the Privacy Policy on your first use of Our Site
following the alterations. We recommend that you check this page regularly to keep up-to-
date.