DATA PROTECTION AND PRIVACY POLICY

Last updated March 2023

This data protection and privacy policy (the “Privacy Policy”) applies to all information provided to or collected by the LIMITLESS MENTORING LLC (the “Company”, “we” or “us”), whether through our website (the “Website”), via email, post, by telephone, in-person and other online channels (hereafter referred to as the “Online Platforms”), as well as in hardcopy format and through verbal communication.

With the following Privacy Policy, we comply with our statutory duty to inform and inform you about the storage of data, the type of data, their purpose and our identity as per the applicable data protection laws, in particular the Federal Act on Data Protection (“FADP”) and – if applicable to your personal data – the European General Data Protection Regulation (“GDPR”).

WHO WE ARE

According to data protection law, responsibility for data processing lies with the Company, which determines whether such processing is to take place, for what purposes it is to take place and how it is to be configured.

The Company is a limited liability company duly incorporated and existing under the laws of Switzerland and registered under ID number CHE-384.943.239 in the commercial register of the State of Vaud and having its registered office at Route de Rolle 38, 1162 St-Prex, Switzerland.

The purpose of the Company is to render services and products in the field of personal development coaching and consulting for individuals focusing on communication and mindset to improve overall performance and quality of life.

We look forward to your visit to our website and your interest in our services.

WHAT INFORMATION DO WE COLLECT

Based on Article 13 of the Swiss Federal Constitution and the data protection regulations of the FADP and the GDPR, every person is entitled to protection of their privacy and to protection against misuse of their personal data. We comply with these terms. Personal data will be kept strictly confidential and will not be sold or passed on to third parties. The details can be found in the following explanations.

Personal data constitute information that can be associated with a specific person. We process various categories of such personal data. The key categories are set out below for your convenience. However, we may also process other personal data in individual cases.

Automated Data The protection of your personal data during the collection, processing and use during your visit to our website is very important to us and takes place within the framework of the legal regulations. Use of websites is usually not possible without providing personal data. When you visit our websites at www.thelimitlessmentoring.com, the browser on your device (computer, laptop, tablet, smartphone, etc.) automatically sends information to the server(s) on which our website is hosted. This information is temporarily stored in a so-called log file on the serve side. The following information is collected without your intervention and stored until it is automatically deleted:

IP address of the requesting computer, as well as device ID or individual device identifier and device type; date and time of access; Message about successful call; name and URL of the retrieved file, date and time of retrieval, as well as amount of data transferred; requesting domain (origin of the request), website from which access is made (referrer URL); the browser used and, if applicable, the operating system of your computer as well as the name of your access provider; Location information, including location data from your mobile device. Please note that on most mobile devices, you can control or disable the use of location services in the mobile device's settings menu. We process the aforementioned data for the following purposes:

ensuring a smooth connection of the website; ensuring comfortable use of our website; evaluating the system security and stability of our website; as well as for other and further administrative purposes. Within the scope of the FADP and the GDPR, our legal basis for processing this data is our legitimate interest as per Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the purposes listed above for data collection.

In addition, we may use cookies and other analysis technologies such as web beacons when you visit our website. Cookies are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site.

Information is stored in the cookies that result in each case in connection with the specifically used terminal device. These cookies allow us to automatically recognize when you return to our website that you have already been with us. However, this does not mean that we immediately become aware of your identity. The use of cookies primarily serves the purpose of statistically recording and evaluating the use of our website and to optimize our offer for you, as well as making your use of our websites more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website.

In addition, we also use temporary cookies that are stored on your end device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize that you have already been with us and what entries and settings you have made so that you do not have to enter them again.

These cookies are automatically deleted after a defined period of time.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. If you do not want us to recognize information about your computer, please set your browser to delete cookies from your computer hard drive, block all cookies, or warn you before a cookie is stored. Please note, however, that the complete deactivation of cookies may lead to the fact that you cannot use all functions of our website.

Collected Data We may also collect personal data about you ourselves or automatically, such as when you order services online, make use of our offers, or procure our services. Such data frequently comprise transaction and behavior data and technical data.

For example, we independently collect personal data about you in the following cases:

you procure one of our services online; you click on a link in one of our newsletters or interact with one of our electronic promotional materials in another way. We may also derive personal data from personal data already available to us, for example by analyzing transaction and behavior data. Such derived personal data frequently comprise preference data. For example, we can analyze the transaction and behavior data collected during purchases online and, on this basis, make assumptions about your personal interests, preferences, affinities. This enables us, for instance, to tailor our offers and information to your individual needs and interests.

We may produce photos, videos, and sound recordings in which you might be featured, for example if you attend public events or workshops, video conferences, courses, presentations, training courses, etc. Such events may be recorded; we will inform you of this at the start of each conversation. If you do not want us to record such conversations, you may terminate the conversation at any time and contact us in another manner (e.g. by e-mail). For more information, please refer to our Terms & Conditions of Services you received when that you have accepted by purchasing our service. These may contain supplementary information about our data processing activities.

Received Data We may receive personal data from third parties, such as from companies or individuals with which we cooperate, persons who communicate with us, or public sources.

For example, we may receive information about you from the following third parties:

third parties if correspondence and discussions concern you; persons close to you (family members, legal representatives, etc.), e.g. your address for deliveries, references, or powers of attorney; credit reference agencies, for example if we wish to obtain information about creditworthiness; swiss Post and address dealers, e.g. for address updates; banks, insurance companies, distribution partners, and other contractual partners for purchases and payments; providers of online services, e.g. providers of Internet analysis services; information services for compliance with statutory requirements such as anti-money laundering and export restrictions; authorities, parties, and other third parties in connection with official and judicial proceedings; public registers such as the debt collection or commercial register, from public offices such as the Swiss Federal Statistical Office, from the media, or from the Internet.

Provided Data Most of the information we collect is information provided directly by you. You often disclose personal data to us yourself, for instance when sending us data or communicating with us. This usually includes:

Member information: email address, username and password; Communication and Contact Information Data: information such as name, job title, company name, department, email address, physical mailing address and telephone number; Professional information: such as your employment background, job title, job description and related information, professional email address, professional telephone number; Transaction information: your contact information, the services you are interested in, your purchasing requirements, your financial information, including credit card or other payment information, such bank account, IBAN, etc.; Responses to surveys: information you provide in responding to a survey on our website, via an app or email, on the telephone or otherwise; and Any other information provided. The provision of personal data is largely voluntary, which means that you are not generally obliged to disclose your personal data to us. However, we do have to collect and process the personal data that are required for processing contractual relationships and fulfilling associated obligations or that are prescribed by law, as we would otherwise be unable to conclude or continue the contract in question.

Throughout the website, there may therefore be forms to request information or to purchase or obtain products and services. These forms typically ask for contact information, financial information, and demographic information. Information from these forms is used to deliver the information, products and services that you request. It may also be used to notify you of future services or opportunities that may be of interest to you.

When completing these forms, please do not supply another person’s personal data (e.g. family members) to us unless we prompt you to do so and you have received that individual’s consent to do so. We will assume that you are authorized to do so and that these data are correct. Please also ensure that these other persons have been informed about this Privacy Policy.

PURPOSE OF DATA PROCESSING

We use personal data to power our services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law:

Power our services. We wish to offer you the best possible service. We therefore collect and process personal data necessary to power our services, which may include personal data collected to improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting. Communicate with you. We wish to remain in contact with you. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback, we need to collect and process your personal data. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with us, you may not opt out of receiving these important notices. Information, marketing and service improvement. We wish to present you with attractive offers. We therefore process personal data for relationship management and marketing purposes, for example to send you written and electronic messages and offers and carry out marketing campaigns. These may comprise our own offers or those of advertising partners. We aim to continuously improve our offers and make them more attractive for you. We therefore also process personal data for this purpose. Process your transactions. We wish to process transactions in a way that is convenient and efficient for you. As such, we may need to collect certain data in order to facilitate these transactions. This data may include your name, as well as information related to your purchases and payment details. Security and fraud prevention. We wish to guarantee your and our security and prevent misuse. We therefore also process personal data for security purposes, to guarantee IT security, to prevent theft, fraud, and misuse, and for evidentiary purposes. Comply with law and protection of rights. We must comply with applicable law — for example, to satisfy tax or reporting obligations, to comply with a lawful governmental request such as court and administrative orders, to establish, exercise or defend our legal rights or for the purpose of legal proceedings, or to prevent and respond to actual or potential fraud or illegal activities. All such cases may concern Swiss law or foreign regulations to which we are subject, as well as self-regulations, industry and other standards, our own corporate governance, or official directives. We may also use personal data for other purposes with your consent.

GROUNDS FOR USING YOUR PERSONAL INFORMATION

We rely on the following legal grounds to process your personal information, namely:

Your Consent: we may (but usually do not) need your consent to use the personal data you provide. You can withdraw your consent at any time by contacting us. Our legitimate interests: we may use your personal data for our legitimate interests, for example when data processing is a central component of our business activity. Compliance with Swiss law and foreign legal obligations: we may use your personal information as necessary to comply with applicable laws and regulations. DATA TRANSFER AND SHARING

A transfer of your data to third parties for purposes other than those listed below does not take place. We only pass on your data to third parties if:

you have given your express consent; this is necessary for the settlement of contractual relationships with you; there is a legal obligation to pass it on; disclosure is required for asserting, exercising or defending legal claims and there is no reason to assume that you have a predominantly legitimate interest in not disclosing your data. We may share personal data with service providers who act on our behalf, our partners and publishers, or others at your direction. Third parties are obligated to only handle personal data according to our instructions and to take suitable measures to ensure data security. In these cases, the amount of data transmitted is limited to the minimum required. We do not share personal data with third parties for their own marketing purposes or sell your personal data.

We use a third-party payment processor to process payments made by or to us. In connection with the processing of such payments, we do not retain any personally identifiable information except for your name and we do not have access to any financial information such as credit card numbers. Rather, this information is provided directly to our third-party processor, Stripe, whose use of your personal information is governed by their privacy policy, which may be viewed at https://stripe.com/us/privacy.

It is also possible that we may disclose personal data to other third parties for their own purposes, for example if you have granted your consent or we are legally obliged or authorized to share such information. In such cases, the data recipient is legally responsible as the controller of the data.

We may also use the following third-party service providers for communicating with you:

Instagram Some of our social networking sites Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) are also integrated on our website. The Instagram plugin can be recognized by the "Instagram button" on our website. If you click on the Instagram button while logged in to the Instagram account, you can link the contents of our websites to your Instagram profile. This allows Instagram to associate the visit to our pages with your user account. We point out that as a provider of our website we do not receive any knowledge of the content of the transmitted data and their use by Instagram. For more information on the Instagram privacy policy, please visit www.instagram.com/about/legal/privacy.

YouTube Our website sometimes uses plugins under / or content from YouTube (belonging to Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA). When you open our website, it connects directly to the servers of YouTube through your browser. This will transmit to YouTube the information that you have accessed our website. If you are logged in to your YouTube account, your visit to our website, as well as all of your interactions with the plugin (eg, clicking the YouTube button), can be associated with your YouTube profile and saved to YouTube - even if you have not YouTube profile, it cannot be ruled out that YouTube will not save your IP address. For more information on YouTube privacy policy, please visit www.google.com/intl/en/policies/privacy. To prevent YouTube from collecting the data when you visit our website, log out before visiting YouTube. To prevent YouTube from gaining general access to your information about websites, you can exclude YouTube plug-ins with an add-on for your browser (e.g., www.youtube.com/user/disconnecters).

Google Drive We use Google Drive (belonging to Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA). Google Drive is a file storage and synchronization service that helps us to store and manage information on existing and potential clients. We process the following data using Google Drive: Name, phone number, e-mail address, address, IP-address, our correspondence with you, information users provide via forms, information related to items purchased and the dates of purchase, events attended and dates of the signup. Google complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. For more information on Google's privacy policy visit https://policies.google.com/privacy.

WhatsApp, Skype, Zoom We use various communication applications, such as WhatsApp, Skype, or Zoom, to communicate with you and collect your personal data, such as your name, your phone number or email, date, time and duration of calls, or chat correspondence. By using these communication applications to communicate with us and providing us with your personal information, you acknowledge and consent to the collection, use, and disclosure of your information as described in this Privacy Policy. For more information on WhatApp’s, Skype, Zoom or any other communication application’s privacy policy please visit their own websites.

Social Links & Recommendations On our website, you may have the option of submitting the respective page to selected social media platforms in order to recommend them within your individual group of friends. After using the respective social icons (click on the Facebook icon, for example), you will be redirected to the respective platform in a new window, which may ask you to log in to your profile first. Thereupon, or during this or even before, only the page contents of the page to be recommended are analyzed exclusively by the platform operator and processed differently depending on the platform (title of the page, picture motif as icon, continuous text). We point out in the context that we have no influence on the data collection of the respective platform, which applies to the registered as well as not registered condition in the respective social media offer. When using the social media recommendations (buttons), you automatically and knowingly agree that the respective social media offers can collect and store data about your person and your usage behavior. We as the provider of the website offered here have no influence on this and, therefore, we hereby release ourselves from any liability with regard to the data collection and storage of third parties.

Web Statistics Collection (Web Statistics Tool) Our website use Google Analytics, a service by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 United States. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. You may refuse the use of cookies by selecting the appropriate settings on your browser.

Newsletter If you choose to register for our newsletter, you consent to our use of your name and email address for the purposes of sending you said newsletter, in accordance with Art. 6 para. 1 p. 1 lit. a GDPR. You may unsubscribe from the newsletter at any time, either by clicking the unsubscribe link located at the bottom of the newsletter, or by sending an email to us with the subject line “unsubscribe newsletter”. We will promptly process your request to unsubscribe and will no longer send you the newsletter.

DATA RETENTION

The data collected will be stored as long as necessary for the relevant purpose or compatible purpose for which we are using it and for any minimum periods which we are required to by law or regulation. We store your data for no longer than necessary in relation to the purpose under which such data was collected.

YOUR RIGHTS

You have a number of legal rights in relation to the personal information that we hold about you. You have the right to object to data processing particularly if we process your personal data on the basis of a legitimate interest and the other applicable requirements are met. You can also object to data processing in connection with direct advertising (e.g. advertising e-mails) at any time. This also applies to profiling, to the extent it is related to direct advertising.

Provided the applicable conditions are met and there are no applicable statutory exceptions, you also have the following rights:

you can request and obtain a copy of your personal data; you can ask that we correct your personal data if it is inaccurate or incomplete or request the deletion or anonymization of your personal data in certain circumstances. Please note that in some circumstances, we are legally entitled to retain it. you can request that we restrict our processing of your personal information in certain circumstances. Please note that in some circumstances, we are legally entitled to retain it. you can withdraw consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so. you can request to receive certain personal data in a structured, commonly used and machine-readable format where applicable. Please note that these rights may be restricted or excluded in individual cases, e.g. if there are doubts about the identity or if this is necessary to protect other persons, to safeguard interests worthy of protection or to comply with legal obligations. Should you wish to request any of the elements above, please contact support@limitlessmentoring.com. We may need to request specific information from you to help us confirm your identity.

If you think that any of your rights have been infringed by us, you may lodge a complaint with the relevant data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch)

DATA SECURITY

We take appropriate technical and organizational security measures to safeguard your personal data, protect you against unauthorized or unlawful processing activities, and to address the risk of loss, unintentional changes, inadvertent disclosure, or unauthorized access. We ensure that your data is protected in a manner commensurate with the risks involved and continuously improve our security measures and adapt them to the current state of the art.

CHANGES TO THIS DATA POLICY

This privacy policy is currently valid.

Due to the further development of our website and offers or due to changed legal or regulatory requirements, it may be necessary to change this Privacy Policy. The current privacy policy can be viewed and printed on our website at any time using the following link www.thelimitlessmentoring.com/privacy. We will actively inform individuals whose contact details are registered with us of any material changes, provided that we can do this without disproportionate effort.

NAME AND CONTACT DETAILS OF THE CONTROLLER

If you have any questions or concerns relating to this Privacy Policy or the processing of your personal data, please contact the Company. We are pleased to help all concerned in connection with the handling of personal data and exercising their rights. For assistance please contact support@limitlessmentoring.com. We are committed to dealing with all questions promptly.