Privacy Policy
This Privacy Policy explains how Dynamic Behavior Science, LLC (“DBS,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information through our Thinkific-hosted website, courses, trainings, products, and related services (the “Services”). DBS determines the purposes and means of processing learner and customer information and generally acts as the data controller or “business,” as those terms are defined by applicable privacy laws.
Thinkific Labs Inc. and/or its applicable affiliate (“Thinkific”) hosts the learning platform and processes learner and customer information for DBS as a data processor or service provider under its agreement and Data Processing Addendum with DBS. Thinkific may also process information for its own disclosed purposes under its policies. Thinkific is responsible for its own processing, systems, and privacy practices. Review Thinkific’s Privacy Policy at https://www.thinkific.com/privacy-policy/ and its Data Processing Addendum at https://www.thinkific.com/dpa/.
1. What information do we collect and what do we do with it?
Depending on how you interact with the Services, we and our service providers may collect: (a) identifiers and contact information, such as name, email address, telephone number, billing address, and account identifiers; (b) account and profile information, such as organization, professional role, credentials, and preferences you choose to provide; (c) transaction information, such as products purchased, purchase date, amount, payment status, and limited payment details supplied by the payment processor; (d) course and continuing-education information, such as enrollment, attendance, progress, quiz or assessment responses and results, evaluations, completion status, and certificates; (e) communications and content you submit, including support requests, survey responses, feedback, and form entries; (f) marketing preferences; and (g) device, log, and usage information collected automatically, such as IP address, browser, operating system, device type, pages viewed, referring pages, session activity, cookie identifiers, and approximate location derived from IP address.
We use personal information to provide and administer accounts, purchases, courses, continuing-education requirements, assessments, certificates, customer support, and requested products; process and document transactions; authenticate users and protect the Services; communicate service, policy, and account updates; personalize and improve the Services; analyze performance and engagement; maintain business and tax records; prevent fraud and misuse; enforce our terms; comply with legal, regulatory, accreditation, and professional obligations; and establish, exercise, or defend legal claims. Where permitted, we may also send information about DBS products, services, surveys, and updates. You may unsubscribe from marketing emails using the link in the message or by contacting us.
2. How do you get my consent?
We process personal information as needed to provide Services you request, complete transactions, satisfy our contractual and legal obligations, protect our legitimate business and security interests, and, where required, based on your consent. Where European data-protection law applies, our legal bases may include performance of a contract, compliance with legal obligations, our legitimate interests (including operating, improving, and securing the Services), and consent where required.
For marketing or another optional purpose, we will request consent when applicable law requires it or otherwise provide a method to opt out. Withdrawing consent does not affect processing already performed and does not prevent processing based on another lawful basis.
How do I withdraw my consent?
If you change your mind after opting in, you may withdraw consent at any time by using an available unsubscribe or preference control or by contacting us at [email protected]. We may need to retain or continue processing certain information where permitted or required by law, including transaction, tax, accreditation, certificate, security, and legal records.
3. Disclosure
We may disclose personal information to service providers that support our platform, payments, communications, analytics, security, professional services, and business operations; to accreditation, continuing-education, credentialing, regulatory, or professional bodies when needed to administer or verify credit and as permitted by law; in connection with a merger, financing, reorganization, sale, or transfer of all or part of our business; to protect rights, safety, security, and prevent fraud; with your direction or consent; or where required or permitted by law, including in response to valid legal process. Service providers may use information only as permitted by their agreements and applicable law. We do not authorize service providers to use learner information for their own unrelated marketing.
4. Payment
If you make a purchase, payment information is collected and processed directly by the payment processor made available at checkout, such as Stripe or PayPal. DBS generally does not receive or store your full payment-card number or security code. We may receive limited transaction details, such as payment status, amount, date, billing contact information, and a card brand or partial account identifier, for accounting, support, fraud prevention, and legal compliance.
Payment processors maintain their own privacy and security practices and process information under their own terms. Review Stripe’s Privacy Policy at https://stripe.com/privacy and PayPal’s Privacy Statement at https://www.paypal.com/us/legalhub/paypal/privacy-full, as applicable to your checkout method and location.
Payment-card processing is subject to applicable payment-industry requirements. DBS does not control and cannot guarantee the security, availability, or practices of an independent payment processor.
5. Third-Party Services
Our principal platform provider is Thinkific, which hosts the site, accounts, course content, enrollment, progress, assessments, and related learner records. Payment services may be provided by Stripe or PayPal, depending on the method available at checkout. Current provider policies are available at: Thinkific Privacy Policy, https://www.thinkific.com/privacy-policy/; Thinkific Data Processing Addendum, https://www.thinkific.com/dpa/; Stripe Privacy Policy, https://stripe.com/privacy; and PayPal Privacy Statement, https://www.paypal.com/us/legalhub/paypal/privacy-full.
We may also use other providers for communications, analytics, video delivery, technical support, security, professional services, and business operations. The providers and features used may change over time. Thinkific maintains information about its subprocessors at https://www.thinkific.com/thinkificsubprocessors/. A third party may collect information directly and may act as an independent controller for some processing under its own privacy policy and terms.
Third-party services are responsible for their own systems, processing, privacy notices, and security practices. DBS does not control and does not warrant or guarantee a third party’s privacy, security, availability, or compliance. Review the provider’s current privacy policy and terms before using its service. Nothing in this paragraph limits responsibility that cannot lawfully be limited.
Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
Personal information may be processed in the United States, Canada, or other countries where DBS or its providers operate. Those countries may have privacy laws different from those where you live. Where applicable law requires a transfer mechanism or additional safeguard, DBS and its providers will use an appropriate mechanism, which may include contractual protections.
Once you leave our website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.
Links
When you click on links on our site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
6. Security
We use reasonable administrative, technical, and organizational safeguards designed to protect personal information within our control, taking into account the nature of the information and the Services. Access is limited to persons and providers with a business need, subject to appropriate obligations.
Payment-card information is submitted to the applicable payment processor rather than stored by DBS as described above. Thinkific, payment processors, and other providers maintain their own security measures. No transmission, storage system, or security measure is completely secure, and DBS cannot guarantee the security of information held or collected by a third party or prevent every unauthorized incident. You are responsible for protecting your account credentials and promptly notifying us of suspected unauthorized use.
Cookies
We collect cookies or similar tracking technologies. This means information that our website’s server transfers to your computer. This information can be used to track your session on our website. Cookies may also be used to customize our website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.
We use cookies to recognize your device, maintain sessions, remember preferences, help secure the Services, and provide a personalized experience.
We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
Web Analysis Tools
We may use web analysis tools that are built into the website to measure and collect anonymous session information.
7. Age of Consent
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
7A. Data Retention
We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to provide accounts and course access; document purchases, completion, certificates, and continuing-education compliance; meet tax, accounting, contractual, accreditation, legal, and dispute-resolution requirements; maintain security and prevent fraud; and enforce our agreements. Retention periods vary by information type and applicable requirements. We delete, anonymize, or securely dispose of information when it is no longer reasonably needed, subject to backup cycles and legal obligations.
7B. Your Privacy Rights
Depending on where you live and subject to applicable exceptions, you may have the right to request access to or a copy of personal information; correction; deletion; restriction of or objection to processing; data portability; withdrawal of consent; information about categories, sources, purposes, and recipients; and review of certain automated decisions. Residents of jurisdictions with applicable U.S. state privacy laws may also have rights to opt out of a sale, sharing for cross-context behavioral advertising, or certain targeted advertising; limit certain uses of sensitive personal information; appeal a denied request; and receive equal service without unlawful discrimination for exercising a privacy right.
To exercise a right, email [email protected] and identify the right requested and the email address associated with your account. We may take reasonable steps to verify your identity and authority before responding. You may use an authorized agent where permitted by law, subject to verification. If information is controlled by an independent third party, we may direct you to that provider. You may also complain to an applicable privacy or data-protection authority. These rights apply only to the extent provided by the law governing the request.
For individuals in the European Economic Area, United Kingdom, or Switzerland, the disclosures in this Policy concerning categories, purposes, legal bases, recipients, retention, international processing, and rights are intended to apply where the relevant data-protection law governs DBS’s processing. For California and other U.S. state residents, the rights described above apply only where DBS and the processing are subject to the applicable state law. This Policy does not concede that a particular law applies where its coverage requirements are not met.
8. Changes to this Privacy Policy
We may modify this Privacy Policy from time to time. We will post the revised Policy with an updated effective date. If a change materially affects how we use information already collected or materially changes your rights, we will provide reasonable additional notice, such as by email to the address associated with your account or by notice within the Services, where required by law.
If our site or course is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
QUESTIONS AND CONTACT INFORMATION
To exercise a privacy right, withdraw consent, appeal a decision where applicable, register a complaint, or ask a question about this Privacy Policy, contact Dynamic Behavior Science, LLC at [email protected]. Please include the email address associated with your account and enough information for us to understand and verify the request.