Privacy Policy

Last updated: [GO-LIVE DATE].

Welcome to our website. Xenia Smith Consulting (“we”, “our” or “us”) respects your privacy and is committed to protecting it.

This Privacy Policy governs your access and use of our website, xeniashub.com, including its subdomains and the personal pages we create and send to individual people, and any content, functionality or services offered through our website or related landing pages (collectively, “Site”). In this Privacy Policy “you” or “your” refers to any individual who accesses our Site. This Privacy Policy is incorporated into and forms part of our Website Terms of Use.

Please Read This Privacy Policy Carefully Before Using Our Website

Please review our Privacy Policy carefully. By using our Site, you acknowledge and agree that your information will be collected, used and disclosed as described in this Privacy Policy. If you do not agree to the Privacy Policy, you must not access or use our Site or Services.

This Privacy Policy sets out how we collect information from you when you visit our Site, either automatically, or through certain voluntary actions you may take while visiting our Site, including but not limited to, accessing, purchasing or downloading any products, content or resources available on our Site or engaging or interacting with us either through this Site (collectively, “Services”).

This Privacy Policy applies to information we collect:

• On this Site;
• In email, chat, text and other electronic message features on our Site;
• Through any downloadable features on our Site;
• When you request a Decision Pack, book a call with us, subscribe to our newsletter, or reply to our emails;
• When you interact with us on third-party websites and services, such as social media platforms, Substack and YouTube.

This Privacy Policy does not apply to information collected by:

• Us offline or through any other means, including on any website we operate that is not part of the Site, or by any third party, including our affiliates and subsidiaries; or
• Any third party including through any content or advertising that may link to or be accessible from or on the Site.

This Privacy Policy also sets out how we use and disclose your information and your rights with respect to your personal information that we collect. If you do not agree to any terms of our Privacy Policy, you agree to no longer use, navigate, access or browse our Site. By continuing to use our Site you are agreeing to the terms of our Privacy Policy.

Age Requirement

Our website is intended solely for users who are of legal age of majority in their own place of residence and can form legally binding contracts under applicable law. By using our site, you represent and warrant that you are of legal age of majority where you reside and can form a legally binding contract under applicable law. This website is not intended for use by children under the age of 13, and we do not knowingly solicit personal data from anyone under the age of 13. If you are under the age of 13, do not access or use our website or related products or services. If you become aware that we have collected data of anyone under the age of 13, please contact us so that we can delete their data in accordance with applicable law. If you are located in Quebec, we require the consent of a parent or legal guardian before knowingly collecting personal information from anyone under the age of 14.

Information We Collect

We collect, use, and disclose personal information as described in this Privacy Policy. Where required, we will obtain your express consent before collecting or using personal information. Here are some examples of the data we collect, however, this may not be a complete list:

Personal Information: Personal identifying information such as your name, email address, and the answers you give in our forms (for example, the decision you are working on).

Financial Information: We do not store or process your financial information directly. All transactions are securely processed through third-party providers (for example, Stripe, including through Substack). Please review their privacy policies for details on how they manage your data.

Computer, Browser and Mobile Information: Computer and connection information such as statistics on page views, traffic to and from the Site, the address of the page you came from, your internet protocol (“IP”) address and your Site log information. If you access our Site via your mobile phone, we may collect information about your device, such as the model and your approximate location (for example, based on your IP address).

Social Media Information: We may access personal information from social networking sites and apps, including, but not limited to, Instagram, Facebook, LinkedIn, TikTok, YouTube and Substack, which may include your name, username on any of these platforms, profile picture and any other public information you have included on any of your social media profiles. If you want to limit this data, review the privacy and security settings of each.

Personal Pages: When you follow, subscribe to or interact with us, we may create a personal page for you at a private link, using public information such as your first name or username and something you have shared publicly. These pages are not listed in search engines and are only shared with you. You can ask us to remove yours at any time by contacting us at xenia@xeniashub.com.

Sensitive Information: We do not request or intentionally collect sensitive personal information, such as social insurance or social security numbers, financial account details, or account log-in credentials in combination with a password or security question. We do not sell sensitive information or use it for advertising. Please do not send us sensitive information through our Site or by email unless we have asked you to do so as part of our Services. If sensitive information is inadvertently submitted to us, we will delete it unless we are required by law to retain it.

How We Collect Your Information

Information You Voluntarily Provide

We collect information you voluntarily and manually provide when you use our Site, such as when you purchase or access Services or certain content on our Site, sign up for our email list or newsletter, submit a form, send us questions, or interact with us through this Site such as when you provide comments, reviews, testimonials or other feedback. Some of the information you manually provide may be personal information, such as your name or email address.

Information from Your Website Browser or Mobile Device

We collect information that is sent to us automatically from your website browser or mobile device, such as your IP address, the name of your operating system, the name and version of your browser, date and time of your visit, page(s) you visit and length of time you spent on each page. The information we receive may depend on your browser or device settings. Information received from your website browser and mobile device typically is not, in and of itself, personally identifiable. However, we may combine it with other information in an attempt to identify you, or we may combine it with information that does identify you.

Do Not Track. Our Site does not respond to browser “Do Not Track” signals. Where required by law, we honour opt-out preference signals such as Global Privacy Control (GPC).

Website Analytics: We use privacy-focused analytics that do not use cookies to count visits to pages on our Site. When you arrive through a link we have posted (for example, on Instagram), the link may carry a short label naming where it was posted, and we may record that label with a form you submit, so we know which places people find us from.

Cookies: Our Site does not use advertising cookies, pixels or similar tracking technologies. Some features embedded on our Site, such as our request forms (Google Forms), our booking tool (Cal.com), our newsletter sign-up (Substack) and our videos (YouTube), are run by those providers and may set their own cookies. Please review their privacy policies. You can also set your browser to refuse cookies. If you have questions, contact us at xenia@xeniashub.com.

Email Communications

How We Use And Disclose Your Information

Use of Information

We generally store your data and transmit it to a third party for processing. However, to the extent we process your data, we do so for legitimate business purposes. Generally, the purpose of collecting your information through our Site is to:

• Provide our Site and its contents to you;
• Provide you with information, products or services that you request from us;
• Carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collection;
• Collect statistical data and analyze trends for our use, and for use by third parties to better understand your needs and interests;
• Improve our Services, marketing and promotional efforts or troubleshoot issues on our Site;
• Contact you with newsletters, information and content we believe will be of interest to you, where you have agreed to receive them;
• Allow you to participate in interactive and social features on our Site;
• Improve the content, functionality and usability of this Site and provide a tailored and personalized experience for you when you visit our Site;
• Prevent fraudulent activities and security breaches;
• Resolve disputes and assist law enforcement when necessary or respond to any legal claims or otherwise comply with our legal obligations; and
• For any other purpose with your consent.

Use of Artificial Intelligence and Automated Tools

We may use artificial intelligence (“AI”) tools provided by third-party service providers to help operate our business and Site, for example to draft or personalize content and communications, or to improve our Services. These tools may process personal information you provide or that we collect, including public information from social media profiles. We do not knowingly enter sensitive personal information into AI tools. We take reasonable steps, such as adjusting account settings where available, to prevent our AI providers from using your personal information to train their general AI models. We do not use AI to make decisions about you without human involvement.

Disclosure of your Information We do not sell your personal information. We may share personal information with trusted third-party service providers and analytics providers for legitimate business purposes, as described below.

We may disclose personal information in the following circumstances:

• To service providers who assist in operating our Site and business, including payment processing, hosting services, email delivery, communications, customer service, and analytics;
• To affiliates or strategic partners where necessary to deliver Services or administer programs;
• To administer your account and communicate with you;
• To analyze trends, improve functionality, and enhance user experience;
• To protect the security, integrity, and legal rights of our business and users, including investigating violations of our policies;
• In connection with a sale, merger, restructuring, or transfer of all or part of our business;
• To comply with legal obligations, respond to lawful requests, or protect the rights, property, or safety of our business, users, or others; or
• With your consent.

Where required by applicable privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), you may request to opt out of the sale or sharing of your personal information by contacting us at xenia@xeniashub.com or using any available opt-out tools on our Site.

Retention of Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, to provide Services, and to comply with applicable legal, accounting, or regulatory obligations. Notes we keep to create a personal page for you are deleted 12 months after our last contact with you, or sooner if you ask.

International Data

Your personal information may be transferred to and maintained on servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. We take reasonable steps to ensure that personal information transferred outside your jurisdiction is protected by appropriate contractual or organizational safeguards, as required by applicable law.

Processing Your Information

We may process personal information directly or through third-party service providers acting on our behalf. In order to carry out our business, it is necessary for us to transmit certain information to third parties. For instance, when you purchase a Service from our Site, your payment information is transmitted to and collected by a third-party payment processor. For a full list of third-party applications we use, please contact us at xenia@xeniashub.com.

In some instances, we may process your information internally. We process personal information for the purposes described in this Privacy Policy, with your consent where the law requires it, or on another basis the law allows, such as to perform a contract with you. Where we need your consent, we ask for it separately from this Privacy Policy and our Terms of Use, and you can withdraw it at any time.

Protection of Your Information We use commercially reasonable measures to protect the personal information you provide to us and the information we collect automatically, including secure (encrypted) connections and reputable third-party payment processors and platforms. Because email is not a secure way to send information, please do not send us sensitive or private information by email unless we have asked you to. No system or transmission of data over the internet or any other public network, and no storage of data, can be guaranteed to be 100% secure. If you are concerned about your personal information, please contact us at xenia@xeniashub.com.

Event of a Breach

In the event of a breach involving personal information under our control, we will assess the nature and scope of the incident and notify affected individuals and any required regulatory authorities in accordance with applicable privacy laws. We will take reasonable steps to investigate, mitigate, and remediate the incident as appropriate.

Your Rights

We respect your rights to your personal information and data. You have the right to access, correct, request restriction or deletion of your information, or request details of how we use your personal information and data collected, as required by applicable law. We do not charge a fee for these requests unless the law allows it, in which case we will tell you the amount in advance. We may ask you to verify your identity before we act on a request. We will respond within the time required by applicable law, subject to any permitted extension. You may also submit a request through an authorized agent, and we may require the agent to provide proof of authorization or other verification of their authority to act on your behalf.

After we verify your identity, you have the right to:

• Update or correct any information you have provided to us by contacting us at xenia@xeniashub.com;
• Request that we confirm what data we hold about you, and for what purposes. You also have the right to confirmation of whether we process your data or deliver your data to third party processors, and for what purposes. We will supply you with copies of your personal information unless doing so would affect the rights and freedoms of others;
• Withdraw or change your consent to our use of your information. In some cases, withdrawing your consent may mean we can no longer provide certain Services or give you full access to our Site;
• Request a digital copy of the data that we hold about you in a commonly used format. We will not charge a fee for this unless the law allows it, in which case we will tell you the amount before we proceed;
• Request that we delete the data that we hold about you. We will do so without undue delay unless an exception applies, such as when keeping your data is required by law or is necessary to establish, exercise or defend legal claims. Deleting your data may mean we can no longer provide certain Services or give you full access to our Site;
• Opt out of marketing emails at any time by clicking the “unsubscribe” link in any newsletter, by replying “unsubscribe” to any email from us, or by contacting us at xenia@xeniashub.com;
• Opt out of receiving any third-party marketing communications or having your personal information used for marketing purposes by contacting us at xenia@xeniashub.com;
• In certain situations, restrict the processing of your data, such as when you contest the accuracy of your data or when you have objected to processing, pending the verification of that objection. When processing has been restricted, we will continue to store your data but will not pass it on to third party processors without your consent, or as necessary to comply with legal obligations or protect your rights, our rights, or those of others; and
• Complain to a supervising authority in your jurisdiction if you believe we are misusing your data or have violated any of your rights under this Privacy Policy or applicable law.

If you wish to have any third parties, including those to whom we have disclosed your personal information, delete your information, you may need to contact those third parties directly. Upon request, we will provide information about the categories of third parties with whom we share personal information, as required by applicable law.

Complaints If you believe we have mishandled your personal information or violated your rights under this Privacy Policy or applicable law, please contact us at xenia@xeniashub.com. We will make reasonable efforts to address your concern promptly. You may also have the right to make a complaint to the applicable privacy regulator in your jurisdiction, such as the Office of the Privacy Commissioner of Canada or the relevant state authority if you are located in the United States. Quebec residents may also file a complaint with the Commission d’accès à l’information du Québec. If you are located in British Columbia or Alberta, you may also file a complaint with the applicable provincial privacy regulator, such as the Office of the Information and Privacy Commissioner for British Columbia or Alberta, where those provincial laws apply instead of federal law.

International Visitors Our Site is intended for users located in Canada and the United States. If you are accessing our Site from outside these countries, including from the European Union, please be aware that your information may be transferred to and processed in Canada or the United States, where privacy laws may differ from those in your country. Where the law of your country requires your consent to this transfer, we will ask for it separately.

U.S. State Privacy Rights

If you are a resident of a U.S. state with its own comprehensive consumer privacy law, such as California, Virginia, Colorado, Connecticut, Texas, or another state with similar legislation, you may have rights similar to those described above, including the right to access, correct, delete, or port your personal information, and to opt out of certain processing, including targeted advertising and profiling. We will honour these rights where applicable law requires it. To exercise these rights, please contact us at xenia@xeniashub.com.

Changes to our Privacy Policy

We may update this Privacy Policy from time to time and will update the “Last Updated” date at the top of this page each time we do. If we make a material change to how we collect, use or disclose your personal information, we will notify you, for example by email or by a notice on our Site, and where the law requires your consent to the change, we will ask for it. You can review the most current version at any time by visiting this page. Your continued use of the Site after an update means you have read the revised Privacy Policy, but it does not replace any consent the law requires us to get from you.

Contact us

We have designated Xenia Smith, Owner, as our Privacy Officer and person in charge of the protection of personal information who is accountable for our compliance with this Privacy Policy and applicable privacy laws. If you have questions about how we handle your personal information, or want to make a request or complaint, you can reach our Privacy Officer at xenia@xeniashub.com.