Last Updated:  01/24/2023

This website is owned and operated by Robin G. Coles (also referred to as “we”, “us”, this “website” or this “site”).

We use the term “services” in this Privacy Policy to refer both to services and products (tangible, intangible, and digital), as applicable.

This Privacy Policy describes our collection, use, and sharing of personal data.

If you are a California resident, there are provisions of this Privacy Policy that are specifically designated for California residents.

Our Privacy Policy applies to all of the services offered by us and our affiliated entities, including services accessed by mobile devices and application programming interface (API), but excludes services that have separate privacy policies which do not incorporate this Privacy Policy.

We do not display personalized ads via third-party cookies on our website. (See below, No Personalized Ads Via Third-Party Cookies)

Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, web beacons (pixel tags), and other methodologies to serve personalized ads.


We may modify this Privacy Policy at any time without prior notice. Please check this page periodically for updates. If any update provides a material change regarding personal data, we will post the material changes here and notify you either by email or by notice on this site.


Personal Data

We use the term “personal data” to refer to any personal information regarding a natural person that may be used directly to identify the person (e.g., name and email address).

Personal data also includes usage data that is automatically collected when you use this site including other interactions with us. Usage data that does not directly identify you by name or include your contact information, may be used to identify that a specific computer or device has accessed our site and which if combined with certain other information could be used to identify you. (See below, AUTOMATICALLY COLLECTED INFORMATION WHEN YOU USE THIS SITE)


When You Provide Personal Data to Us

We collect personal data at the time you provide it to us.  We may collect personal data through sign-up forms and as part of your registration for an account, product, or service, promotion, or contest from this website.  Personal data that we collect may vary with each sign-up or registration.  As indicated above, we may collect publicly available personal data posted on social media profile information including photos both directly and through the use of contact management applications.

Automatically Collected Information When You Use This Site

We and/or our third-party service providers collect device information, IP addresses, and other usage data about your computer or device and usage data as you use this site and track across third-party websites, including your interactions with emails we send, and via social media platforms, third-party platforms, third-party websites, applications, and integrations, and services of our marketing partners.  This data may be passively or automatically collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies, web beacons, and other similar methodologies. (See below, COOKIES AND WEB BEACONS)


Generally, we may use and process your personal data for the performance of the services or transaction for which it was given and for the basic purpose of this site.

We may use your personal data (i) in connection with our products, services, or promotions we may offer, (ii) our private, internal reporting for this site, and security assessments for this site to (iii) monitor and improve the operation of this site, market our services, improve the quality of our services; and (iv) for educational, research, analytics, networking, social, and other business purposes. We may also send you email messages related to site updates and certain site features or your activity on this site.

To assist us with these uses, we may supplement the data we collect from you with information from other sources including our customers, other referral sources, and publicly available sources (e.g., social media).

This Privacy Policy does not place any restriction on our use of anonymized, de-identified or aggregated information we may create based on information that you submit.

We use, process, and archive personal data including usage data in the United States and in other countries that may not have data protection laws as protective as those in your location.

We may also send you messages related to certain features or your activity on this site.  We may also send you news or updates about changes to our site or services.  By default, you will receive these messages via email.


We may share your personal data with your consent and otherwise, as follows:

Within our Family of Companies

We and our subsidiary and affiliated companies may share your personal data among and between each other for the purposes described in this Privacy Policy.

In Connection with Business Transfers

If we sell or transfer a business unit (such as a subsidiary) or an asset (such as a website) to another company (including in connection with any bankruptcy or similar proceedings), we will share your personal data with such company and will require such company to use and protect your personal data consistent with this Privacy Policy. We may also share your personal data with companies that were formerly wholly or partly included in our family of companies to whom we provide services during a transition period following separation.

With Providers (See below, NO PERSONALIZED ADS VIA Third-Party Cookies)

We may retain other companies and individuals to perform services on our behalf and we may collaborate with other companies and individuals with respect to research, products or services, and marketing (collectively, “Providers”). These third parties may be provided with access to personal data needed to perform their functions, but they may not use such data other than on our behalf or subject to contracts that protect the confidentiality of the data. Examples of Providers include credit card processing companies, customer service and support providers, email and SMS vendors, data analytics firms, web hosting and development companies, and fulfillment companies. Providers also include our co-promote partners for products that we jointly develop and/or market with other companies. Some Providers may collect personal data on our behalf on our site.

To Comply with Law and Our Duty to Protect

We reserve the right to disclose your personal data as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served on us, or to protect the safety, rights, or property of us, our customers, the public, or others.



“Cookies” are tiny pieces of information stored by your browser on your computer’s hard drive.  Cookies are also used to customize content based on your browser.  Most browsers are initially set to accept cookies. If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies. Please remember, however, that cookies may be required to allow you to use certain features of our site.

We may use cookies and other data collection methodologies discussed below to collect personal data and usage data to assist with navigation, monitoring site usage, and web traffic, assist with our promotional and marketing efforts and personalized ads, and customize and improve our site and services.

Web Beacons

Web beacons (sometimes called single-pixel gifs or clear gifs) are used to assist in delivering cookies, and they allow us to count users who have visited pages of our site. We may include Web Beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.

No Personalized Ads Via Third-Party Cookies

We do not partner with third-party advertising networks to either display personalized ads on our website or to manage our advertising on other sites via the use of third-party cookies and other third-party tracking devices. We reserve the right to serve personalized ads that are based solely on first-party cookies and other tracking devices from this site.

How to Manage Cookies

You can control the placement of cookies and other data collection methodologies for purposes of opting out. You should note that although most browsers are initially set up to accept cookies, you may be able to change your browser settings to cause your browser to refuse first party or third-party cookies or to indicate when a third-party cookie is being sent.  However, disabling or limiting cookies may cause certain features of this website to not function properly or optimally. Check your browser’s “Help” files or other similar resources to learn more about handling cookies on your browser.  In addition, visit –>

Network Advertising Initiative (NAI)

Some companies that use cookies to collect information about your online activities are members of NAI, which offers a single location to opt out of receiving personalized ads from member companies. To opt out of information collection by NAI member companies, or to obtain information about the technologies they use or their own privacy policies, please visit the NAI consumer opt-out page: –>

Digital Advertising Alliance (DAA)

DAA member advertising associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties, please visit DAA Consumer Opt-Out page –>

Opting Out with Ad Choices for Mobile Devices

When using mobile applications, you may receive personalized in-application advertisements. Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system (iOS for Apple phones, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of personalized in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of these advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.


We may participate with third-party analytics partners to monitor and analyze Web traffic and to keep track of user behavior on this site via third-party cookies. These third-parties place or recognize a unique third-party cookie on your browser, and they may use web beacons (pixel tags). (See above COOKIES AND WEB BEACONS)

Google Analytics is a third-party web analysis service that may use third-party cookies and web beacons (pixel tags).  Google utilizes the data collected to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services.  Information collected: personal data including usage data and cookie data. You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at –>


We will implement and maintain administrative, technical, and physical safeguards to protect information that we collect.  Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure.  We do not, and cannot, ensure or warrant the absolute security of your information.


We will retain your personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the site to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to the enforcement of the site Terms of Use and other contractual obligations, applicable statutes of limitations, litigation or regulatory investigations).


Any personal data which we may collect on this site will be stored and processed in our servers located only in the United States.  By using this site, if you reside outside the United States, you consent to the transfer of personal data outside your country of residence to the United States.


We reserve the right to permit you to access your personal data in any account you establish with this site for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.


We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site.  Consistent with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13.  If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact our site (see below, CONTACT US), and be sure to include in your message the same login information that your child submitted.


Minors who reside in California and are registered users for any service provided by this site may remove or request us to remove any content or information they have posted to this site. Please understand that any such removal does not ensure complete or comprehensive removal of the posted information (if, for example, the content or information is “invisible” to others but remains on our servers in some form. (See below, CONTACT US)


Do Not Track Requests

We do not respond to “Do Not Track” signals at this time.

Your Choices

You have certain choices about your personal data. Where you have consented to the processing of your personal data, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt-out, we may still collect and use non-personal data regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.

Sensitive Personal Data

Sensitive personal data includes social security number; passport number; financial account credentials; precise geolocation; racial, ethnic, or religious information; contents of data subject’s emails (with other entities other than us) and genetic data. Publicly available information, as defined under the CPRA, is not considered sensitive personal data. We do not require or request sensitive personal data of any sort, however we may be exposed to sensitive personal data that you voluntarily choose to share with us, in which case we will only use sensitive data for the purpose you provided it or under applicable law, or until otherwise requested by you.

Selling or Sharing Personal Data

We do not sell your personal data, including sensitive personal data, or share it for monetary gain. However, we may disclose your personal data to a third party (as defined in the Policy) for a business purpose whether or not for monetary or other valuable consideration. When we do so, we enter a contract that describes the business purpose and requires the recipient to both keep that personal data confidential and not use, sell or disclose it for any purpose except for performing the contract.

Categories of Personal Data Collected

California residents have the right access personal data by requesting to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during past 12 months, and a description of the categories of personal data shared.  To make such a request, please send an email to the email address provided in our contact information below and include the phrase “California Privacy Request” in the subject line, the domain name of the Web site you are inquiring about, along with your name, address, and email address. We will respond to you within thirty days of receiving such a request. (See below EXERCISING YOUR RIGHTS AND CHOICES and CONTACT US)

Data Portability Rights

You have the right to request us to transfer your personal data to another organization, to the extent requested by you, provided that it is technically feasible. (See below EXERCISING YOUR RIGHTS AND CHOICES and CONTACT US)

Deletion Rights

You have the right to request that we delete any of your personal data that we collected from you and about you, and retained, subject to certain exceptions (see below). When applicable, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless any lawful exception applies. We will also notify third parties to whom we shared your personal data to delete your information from their records, unless this proves as impossible or involves disproportionate effort. (See below EXERCISING YOUR RIGHTS AND CHOICES and CONTACT US)

Data Correction Rights

You have the right to request that we correct any inaccurate personal data about you that we collected. When applicable, once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct (and direct our service providers to correct) your personal information, unless any lawful exception applies. You can make a request to us as described below. We will also notify third parties to whom we shared your personal data to delete your information from their records unless this proves as impossible or involves disproportionate effort. (See below EXERCISING YOUR RIGHTS AND CHOICES and CONTACT US)

Opt-Out Request Rights

You have the right to object to the the sharing of your personal data to third parties, or to withdraw your consent to share (in circumstances where such consent was given by you) at any time. Once we receive and confirm your verifiable consumer request, we will cease the sharing of your information (and direct our service providers to do so), unless any lawful exception applies. In addition, you have the right to request us to cease from using automated decision-making technology and profiling. Please note that there may be circumstances in which we are entitled by law to continue to share your data. Also note that your withdrawal of consent shall not affect our right to request your consent to such share again after twelve (12) months.

Limit Use Request Right

You have the right to request us to limit the use or disclosure of certain sensitive personal information we collected about you to uses necessary to provide you the services, and for certain business purposes. Please note that you may only object to the use and disclosure of a sensitive personal information we collected or processed for the purpose of inferring characteristics about you. Once we receive and confirm your verifiable consumer request, we will limit the use or disclosure of your data (and direct our service providers to do so), unless any lawful exception applies. Please note that your request to limit the use or disclosure of Sensitive Personal Information shall not affect our right to request your consent to such use or disclosure again after twelve (12) months.

Exercising Your Rights and Choices

To exercise your rights described above, please submit a verifiable request to us by email (See below CONTACT US). Please be advised that depending on the type of request you make, certain exceptions may apply according to the applicable law, and we reserve the right to exercise those, when applicable. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child. You may only make such a request for data portability twice within a 12-month period. Your request must provide sufficient information that allows us to (i) reasonably verify that you are the person about whom we collected personal data or an authorized representative of yours, and (ii) to properly understand, evaluate, and respond to it. (See below CONTACT US)

Response Timing and Format

We strive to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. For data portability requests, we will select an easily understandable format to provide your personal data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


We will not discriminate against you for exercising any of these additional rights applicable to California residents, unless specifically authorized by applicable law.


We do not review or control third-party websites that link to or from this site, we are not responsible for their content, and we do not represent that their content is accurate or appropriate. Your use of any third-party site is on your own initiative and at your own risk and may be subject to the other websites’ terms of use and privacy policy.


We do not review or control third-party websites that link to or from this site, we are not responsible for their content, and we do not represent that their content is accurate or appropriate. Your use of any third-party site is on your own initiative and at your own risk and may be subject to the other websites’ terms of use and privacy policy.


If you would like to exercise any individual rights, please contact us at this phone number: 339-532-8334. We will respond to your request consistent with applicable law.

If you have any questions or concerns regarding this Privacy Policy, please contact us.

Robin G Coles
Attn: Compliance
Street Address: 5 Michaels Mall, Unit 461
City, State, Zip: Winthrop, MA 02152

Notice: This document is Copyright © Chip Cooper of the law firm of Jones & Haley, P.C., and licensed for use by the owner of this website under distribution rights granted to All rights reserved worldwide. No part of this document may be copied, reprinted, reproduced, or transmitted in any form or by any means without the prior written permission of the copyright owner.