PRIVACY STATEMENT

Date of Last Revision: Aug 7, 2020

This Privacy Policy describes the data protection practices of ED KPOP Online Training (“ED”, “we”, “us”, or “our”) by Counter Culture Company, Ltd. This Privacy Policy applies to information that we collect and use about you when you access or use the ED website or other online or mobile service that links to or otherwise presents this Privacy Policy to you. We refer to these products and services collectively as the “Services.” Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at [email protected]. Your use of our Site is also governed by our Terms of Use, and the definition of the terms used in this Privacy Policy is defined herein or in the Terms of Use.

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1. What information do we collect and what do we do with it?

When you enroll as a student or subscriber (“learner”) on our site or related courses, as part of the enrolling process, we collect the personal information you give us such as your name and email address.

• The Services you use or processing your orders
• Requests or questions you submit to us via online forms, email, or otherwise
• Your participation in sweepstakes, contests, or surveys
• Any reviews that you submit about the Services
• Account registration and administration of your account
• Uploads or posts to the Services
• Requests for customer support and technical assistance

Information about you

While parts of the Services may not require you to provide any information that can directly identify you by name (such as if you choose to browse the website without logging in), the specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes:

• Email address
• Name, if you choose to provide it
• Log-in credentials, if you create a ED account
• Billing information, such as shipping address of a gift card recipient, credit or debit card number, verification number, and expiration date
• Information about purchases or other transactions with us
• Information about your customer service interactions with us
• Demographic information such as your gender or other information you choose to provide as part of your ED profile
• User-generated content you provide to us, such as when you comment on content on the Services, respond to a survey request, review a class, or participate in the public forums
• Classes in which you enroll
• Any other information you choose to directly provide to us in connection with your use of the Services

Information about others

If you request that your purchase be provided to someone other than yourself (such as a gift recipient), we use the information you provide about the other person to fulfill your request.

Email marketing

We may send you emails about our site and related course(s), registration, course content, your course progress or other updates. We may also use your email to inform you about changes to the course, survey you about your usage, or collect your opinion.

2. How do you get my consent?

When you provide us with personal information to become a learner on our site, make a purchase, participate in the course, or apply to our newsletter, you imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at [email protected].

3. Disclosure

We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.

4. Thinkific

Our course and site is hosted by Thinkific Labs Inc. (“Thinkific”). They provide us with the online course creation platform that allow us to sell our product/services to you.

Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.

Payment

If you make a purchase on our site, we use a third party payment processor such as Stripe or Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

All direct payment gateways 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 credit card information by our site and related courses and its service providers.

For more insight, you may also want to read Thinkific’s Terms of Service here https://www.thinkific.com/resources/privacy-policy/ or Privacy Statement here https://www.thinkific.com/resources/terms-of-service/.

5. Third Party Services

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

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.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our course 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 course 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

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

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 and provide you with a personalized experience.
• We also use cookies to attribute visits to our websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors.
• Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads. For more information about targeted or behavioral advertising, please visit https://www.networkadvertising.org/understanding-online-advertising.
• Opting out: You can opt out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.
• 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 like Google, Facebook, Amplitude, Fullstory that are built into ED website to measure and collect anonymous session information.

7. CHILDREN’S PRIVACY

The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

8. DATA SUBJECT RIGHTS AND CHOICES

Depending on your jurisdiction of residence, you may have certain rights with respect to your information as further described in this section.

Your Legal Rights

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Information” section below at any time. Your local laws (e.g., in the EU) may permit you to request that we :

• provide access to and/or a copy of certain information we hold about you
• prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
• update information which is out of date or incorrect
• delete certain information which we are holding about you
• restrict the way that we process and disclose certain of your information
• transfer your information to a third party provider of services
• revoke your consent for the processing of your information

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

Marketing Communications and Sharing

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications regarding classes in which you are enrolled.

9. LEGAL BASES FOR USE OF YOUR INFORMATION

The legal bases for using your information as set out in this Privacy Policy are as follows:

• Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the terms of service of our websites which you accept by browsing the websites/registering; and/or our contract to provide our Services to you);
• Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website and applications; operate our business and our Services; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services);
• Where we are required to process information in accordance with an EU Member State legal obligation; or
• Where we have your consent, in accordance with applicable law.

10. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Date of Last Revision" included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

11. QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact us at [email protected]