Last updated: October 16, 2020

This Privacy Policy describes BoldlyInternational.com and BoldlyPanama.com policies and procedures on the collection, use, and disclosure of member information when members access the information on our website. This document informs you, the member, about your privacy rights and protections under the law.

BoldlyInternational.com and BoldlyPanama.com will use the data of members to provide and improve service. By utilizing this service, the member agrees to the collection and use of information in accordance with this privacy policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in the plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for each BoldlyInternational.com and/or BoldlyPanama.com to access the information and service provided through the website.

Business, for the purpose of the Data Protection Act of 1998, the CCPA (California Consumer Privacy Act) and the EU (European Union) General Data Protection Regulation (GDPR)  refers to BoldlyInternational.com  as the legal entity that collects members’ personal information and determines the purposes and means of the processing of members’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to BoldlyInternational.com LLC, 23 N PH Casa Bonita, Veracruz, Panama.

For the purpose of the GDPR, BoldlyInternational.com  is the data controller.

Consumer, for the purpose of the GDPR, consumer means a natural person residing anywhere on the globe. iled in the USA who is outside the USA for a temporary or 

Cookies are small files that are placed on a member’s computer, mobile device or any other device by a website, containing the details of the browsing history on that website among its many uses.

Country refers to Panama, the United States, Canada, Great Britain, Germany, China, Malaysia, Mexico, Japan, France, Russia, Thailand, Singapore, India, Spain, Italy, Costa Rica, Colombia, Brazil, and any other duly recognized country on Earth.

Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the BoldlyInternational.com LLC as the legal entity which alone or jointly with others determines the purposes and means of processing personal data.

Device means any device that can access the BoldlyPanama.com website, including owned links, such as a computer, a cellphone, or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.

Facebook Fan Page is a public profile named Boldly Panama specifically created by the BoldlyInternational.com on the Facebook social network, accessible from https://www.facebook.com/BoldlyPanama/

Personal Data is any information that relates to an identified or identifiable member of Boldly International.com.

For the purposes of GDPR, Personal Data means any information relating to the member such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.

For the purposes of all other regulations covering, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a BoldlyPanama.com member.

Sale, BoldlyInternational.com will not sell, rent, release, disclose, communicate orally or in print, any information about a members’ personal data.

Service refers to the website, BoldlyPanama.com.

Service Provider means any natural or legal person who processes the data on behalf of BoldlyInrternational.com. It refers to third-party companies or individuals employed by the BoldlyInternational.com to facilitate information, to members on behalf of the BoldlyInternational.com. For the purpose of the GDPR, Service Providers are considered Data Processors.

Third-party Social Media Service refers to any website or any social network website through which a member can log in or create an account to use the information provided by BoldlyPanama.com.

Usage Data refers to data collected automatically, either generated by the use of the Information or from the BoldlyPanama.com infrastructure itself (for example, the duration of a page visit).

Website refers to BoldlyPanama, accessible from BoldlyPanama.com

You mean the individual accessing or using the membership service of BoldlyPanama.com, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), members can be referred to as the Data Subject or as the User as you are the individual using the services of BoldlyPanama.com.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using BoldlyPanama, you may be asked to provide certain personally identifiable information that can be used to contact or identify members. Personally, identifiable information may include, but is not limited to:

Email address

First name and last name

Usage Data

Usage Data

Usage Data is collected automatically when using the membership, BoldlyInternational.com, and BoldlyPanama.com.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of BoldlyPanama.com that members visit, the time and date of the visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When members access the information by or through a mobile device, BoldlyInternational.com may collect certain information automatically, including, but not limited to, the type of mobile device members use, the mobile device’s unique ID, the IP address of the members’ mobile device, the mobile operating system, the type of mobile Internet browser used, unique device identifiers and other diagnostic data.

BoldlyInternational.com may also collect information that members’ browser sends whenever members visit our BoldlyPanama.com or when members access the website of BoldlyPanama.com by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity of members and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on a members’ device. Members can instruct their browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if a member does not accept Cookies, that member may not be able to access some parts of BoldlyPanama.com’s information. Unless a member has adjusted their browser setting so that it will refuse Cookies, BoldlyPanama.com and BoldlyInternationaol.com may use Cookies.
  • Flash Cookies. Certain features of BoldlyPanama.com may use local stored objects (or Flash Cookies) to collect and store information about a member’s preferences according to their activity on BoldlyInternational.com or BoldlyPanama.com. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how members can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
  • Web Beacons. Certain sections of BoldlyPanama.com and emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit BoldlyPanama.com, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on a member’s personal computer or mobile device when they go offline, while Session Cookies are deleted as soon as a member closes their web browser. Learn more about cookies: What Are Cookies?.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: BoldlyPanama.com

Purpose: These Cookies are essential to provide members with services available through BoldlyPanama.com and to enable members to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that members have asked for cannot be provided, and BoldlyPanama.com only use these Cookies to provide members with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: BoldlyPanama.com

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: BoldlyPanama.com

Purpose: These Cookies allow BoldlyPanama.com to remember choices members make when they use the BoldlyPanama.com, such as remembering a member’s login details or language preference. The purpose of these Cookies is to provide members with a more personal experience and to avoid members having to re-enter preferences every time BoldlyPanama.com is accessed.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

BoldlyPanama.com and BoldlyInternationao.com  may use Personal Data for the following purposes:

To provide and maintain information offerings, including monitoring  the usage of information provided by Boldly Panama.com and Boldly International.com.

To manage a Member Account: to manage a member’s registration as a user of BoldlyPanama.come. The Personal Data provided can give members access to different functionalities of BoldlyPanama.com available to you as a member user.

For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services members have purchased or of any other contract with BoldlyPanama.com through membership.

To contact members: To contact a member by email, telephone call, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide members with news, special offers, and general information about other goods, services, and events offered by BoldlyPanama.com that are similar to those already purchased or enquired about unless members have opted not to receive such information.

To manage member requests: To attend and manage requests made by members to BoldlyPanama.com.

For business transfers: We may use personal member information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or another sale or transfer of some or all BoldlyInternational.com assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by BoldlyInternational.com about our member users is among the assets transferred.

For other purposes: BoldlyInternational.com may use member information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the offerings of BoldlyPanama.com, products, services, marketing, and member experience.

BoldlyInternational.com may share members’ personal information in the following situations:

  • With Service Providers: We may share members’  personal information with other Providers to monitor and analyze the use of our offerings, for payment processing, and to contact members.
  • For business transfers: BoldlyInternational.com  may share or transfer members’ personal information in connection with, or during negotiations of, any merger, sale of BoldlyInternational.com  assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: BoldlyInternational.com may share member information with affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include the parent company, BoldlyInternationanl.com LLC, and any other subsidiaries, joint venture partners, or other companies that ee control or that are under common control with us.
  • With business partners: We may share members’ information with business partners to offer members certain products, services, or promotions.
  • With other users: when members share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If members interact with other users or register through a Third-Party Social Media Service, members’ contacts on the Third-Party Social Media Service may see your name, profile, pictures, and description of your activity. Similarly, other users will be able to view descriptions of members’ activity, communicate with members, and view your profile.
  • With your consent: We may disclose the personal information of members for any other purpose with your consent.

Retention of Your Personal Data

BoldlyInternational.com LLC will retain the personal data of members-only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use member personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

BoldlyInternational.com LLC will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or BoldlyInternational.com LLC is  legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Member information, including Personal Data, is processed at BoldlyInternational.com LLC’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from of your jurisdiction.

Your consent to this Privacy Policy followed by the submission by a member of such information represents your agreement to that transfer.

BoldlyInternational.com LLC  will take all steps reasonably necessary to ensure that the personal data of members is treated securely and in accordance with this Privacy Policy and no transfer of a member’s Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of member data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If BoldlyInternational.com LLC is involved in a merger, acquisition, or asset sale, the personal data of members may be transferred. We will provide notice before the member’s personal data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, BoldlyInternational.com LLC may be required to disclose the personal data of members if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

BoldlyInternational.com LLC may disclose personal data of members in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of BoldlyInternational.com LLC
  • Prevent or investigate possible wrongdoing in connection with the offerings of BoldlyPanama.com
  • Protect the personal safety of users of the BoldlyPanama.com or the public
  • Protect against legal liability

Security of Your Personal Data

The security of a member’s personal data is important to BoldlyInternational.com LLC, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While BoldlyInternational.com LLC strives to use commercially acceptable means to protect the personal data of members, we cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service providers have access to your personal data only to perform their tasks on behalf of BoldlyInternational.com LLC and are obligated not to disclose or use it for any other purpose.

Email Marketing

We may use the personal data of members to contact them with newsletters, marketing or promotional materials, and other information that may be of interest to members. You may opt-out of receiving any, or all, of these communications from BoldlyInternational.com and BoldlyPanama.com by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service providers to manage and send emails to members including Active Campaign. Their Privacy Policy can be viewed at https://www.activecampaign.com/legal/privacy-policy

Payments

We provide paid products and/or information within BoldlyPanama.com In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to the third-party payment processors for BoldlyInternational.com LLC whose use of personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information. PayPal is the vendor used by BoldlyInternational.com LLC and their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given your consent for processing personal data for one or more specific purposes.
  • Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which BoldlyInternational.com is subject.
  • Vital interests: Processing personal data is necessary in order to protect vital interests or of another natural person.
  • Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in BoldlyInternational.com and BoldlyPanama.com.
  • Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by BoldlyInternational.com LLC.

In any case, the BoldlyInternational.com LLC will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

BoldlyInternational.com LLC undertakes to respect the confidentiality of the personal data of members and to guarantee that members can exercise their rights.

You have the right under this Privacy Policy, and by law, if you are within the EU, to:

  • Request access to your personal data. The right to access, update, or delete the information BoldlyInternational.com LLC has on any member. Whenever made possible, members can access, update or request deletion of their personal data directly within the account settings section. If you are unable to perform these actions yourself, please contact BoldlyInternational.com  to assist you. This also enables members to receive a copy of the personal data BoldlyInternational.com holds about members.
  • Request correction of the personal data that BoldlyInternational.com LLC holds about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your personal data. This right exists where BoldlyInternational.com LLC is relying on legitimate interest as the legal basis for our processing and there is something about the particular situation of a member, which makes the member want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. Personal data for BoldlyInternational.com LLC is currently processed in the following countries: Canada, United States, Panama, and Germany.
  • Request erasure of your personal data. Members have the right to ask BoldlyInternational.com LLC  to delete or remove personal data when there is no good reason for us to continue processing it.
  • Request the transfer of your personal data. We will provide members, or to third-party members have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for BoldlyInternational.com to use or where ee used the information to perform a contract with you.
  • Withdraw Your consent. Members have the right to withdraw consent on using your personal data. If a member withdraws consent, BoldlyPanama.com may not be able to provide you with access to certain specific functionalities of the website and information.

Exercising of Your GDPR Data Protection Rights

A member may exercise their rights of access, rectification, cancellation and opposition by contacting BoldlyInternational.com. Please note that we may ask a member to verify their identity before responding to such requests. If you make a request, BoldlyInternational.com will try our best to respond to you as soon as possible.

Members have the right to complain to a Data Protection Authority about BoldlyInternational.com’s collection and use of your personal data. For more information, if a member is  in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

BoldlyInternational.com  is the Data Controller of members’ personal data collected while using the BoldlyPanama.com. As the operator of the Facebook Fan Page https://www.facebook.com/BoldlyPanama/, the BoldlyInternational.com and the operator of the social network Facebook are Joint Controllers.

BoldlyInternational.com LLC has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php.

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the BoldlyPanama.com Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about member users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records, and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page, and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

CCPA Privacy

This privacy notice section for California residents supplements the information contained in BoldlyInternational.com LLC’s Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular member  or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by BoldlyInternational.com LLC, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if a member provided such personal information directly to BoldlyInternational.com or BoldlyPanama.com..

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA’s scope, such as: 
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from members. For example, from the forms members complete on BoldlyPanama.com, preferences members express or provide through our website, or from member purchases on BoldlyPanama.com.
  • Indirectly from members. For example, from observing member activity on BoldlyPanama.com.
  • Automatically from members. For example, through cookies we or our service roviders set on your device as members navigate through our BoldlyPanama.com..
  • From Service Providers. For example, third-party vendors for payment processing, or other third-party vendors that BoldlyInternational.com uses to provide the information and research to members.

Use of Personal Information for Business Purposes or Commercial Purposes

BoldlyInternationsl.com LLC  may use or disclose personal information ee collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

  • To operate our membership site and provide members with information and research about Panama..
  • To provide members with support and to respond to member inquiries, including to investigate and address concerns and monitor and improve our offerings about Panama..
  • To fulfill or meet the reason members provided the information. For example, if you share your contact information to ask a question about BoldlyPanama.com, we will use that personal information to respond to your inquiry. If a member provides their personal information to purchase a product or service, BoldlyInternational.com will use that information to process payment and facilitate delivery.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to members when collecting personal information or as otherwise set forth in the CCPA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If BoldlyInternational.com LLC  decides to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed but reflects our good-faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When BoldlyInternational.com discloses personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that BoldlyInternational.com LLC may have received some kind of benefit in return for sharing personal Iinformation, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold but reflects our good-faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Share of Personal Information

We may share your personal information identified in the above categories with the following categories of third parties:

  • Service Providers
  • Payment processors
  • Our affiliates
  • Our business partners
  • Third-party vendors to whom members or member agents authorize BoldlyInternational.com to disclose a member’s personal information in connection with products or service provide to members by BoldlyPanama.com

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, members (or your authorized representative) may submit a request to BoldlyInternational.com by contacting BoldlyInternational.com.

If You have reason to believe that a child under the age of 13 (or 16) has provided BoldlyPanama.com with personal information, please contact ss with sufficient detail to enable us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If a member is a resident of California, members have the following rights:

  • The right to notice. You have the right to be notified which categories of personal data is being collected and the purposes for which the personal data is being used.
  • The right to request. Under CCPA, members have the right to request that BoldlyInternational.com discloses of information to members about our collection, use, sale, disclosure for business purposes and share of personal information. Once BoldlyInternational.com receives and confirms a member request, we will disclose to You: 
  • The categories of personal informatio collected about a member
  • The categories of sources for the personal information collected about you
  • Our business or commercial purpose for collecting or selling that personal information
  • The categories of third parties with whom we share that personal information
  • The specific pieces of personal information collected about a member
  • If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to Youmembers: 
  • The categories of personal information categories sold
  • The categories of personal information categories disclosed
  • The right to say no to the sale of personal data (opt-out). Members have the right to direct BoldlyInternational.com to not sell personal information. To submit an opt-out request please contact BoldlyInternational.com.
  • The right to delete personal data. You have the right to request the deletion of your personal data, subject to certain exceptions. Once we receive and confirm your request, BoldlyInternational.com will delete (and direct Our Service Providers to delete) the personal information of a member from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for BoldlyInternational.com or Our Service Providers to: 
  • Complete the transaction for which we collected the personal information, provide a good or service that a member requested, take actions reasonably anticipated within the context of our ongoing business relationship with a member, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if a member previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on a member’s  relationship with BoldlyInternational.com LLC.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by: 
  • Denying goods or services to a member
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to a member
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, members can contact Us:

  • By email: Legal@BoldlyInternational.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to a member’s  personal information.

Your request to BoldlyInternational.com  must:

  • Provide sufficient information that allows BoldlyInternational.com to reasonably verify you are the person about whom we collected personal information or an authorized representative
  • Describe your request with sufficient detail that allows BoldlyInternational.com to properly understand, evaluate, and respond

We cannot respond to a  request or provide a member with the required information if we cannot:

  • Verify your identity or authority to make the request
  • And confirm that the personal information relates to the specific member

We will disclose and deliver the required information free of charge within 45 days of receiving a verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures BoldlyInternational.com provides will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, BoldlyInternational.com will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of your personal information. Once BoldlyInternational.com  receives and confirms a verifiable consumer request from the member, we will stop selling your personal information. To exercise your right to opt-out, please contact BoldlyInternational.com at Legal@BoldlyInternational.com.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

BoldlyInternational.com does not respond to Do Not Track signals.

However, some third party websites do keep track of member’s browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with BoldlyInternational.com can request information once a year about sharing personal data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if, as a member of BoldlyInternational.com are a California resident, you can contact us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact BoldlyInternational.com using the contact information provided below, and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

BoldlyInternational.com may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise our members to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

Changes to this Privacy Policy

We may update the  Privacy Policy of BoldlyInternational.com from time to time. We will notify our members of any changes by posting the new Privacy Policy on this page.

We will let our members know via email and/or a prominent notice on BoldlyInternational.com, prior to the change becoming effective and update the “Last Updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: Legal@BoldlyInternational.com