This Privacy Policy (“the Policy”) set out below will govern the protection and processing of your personal data that is collected or submitted by using the website https://takeclass.io, mobile application, or other online or mobile service (“Online Services”) that links to or otherwise presents this Policy to you (regardless of where you visit it from).
The Online Services are owned and operated by Takeclass Holding Limited, a company registered at Griva Digeni 115, 3101, Limassol, Cyprus (“the Company”).
Please read this Policy carefully. By further use of Online Services you are deemed to have read, understood, agreed to and consented to the Policy. This Policy should be read alongside the Terms of Service found.
Any information (including personal data) submitted to the Online Services by a user, will be handled by us and transmitted to us. Please note that we need certain types of information so that we can provide services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our services.
2. Collection of Information
We collect information that you provide directly to us through Online Services, including, but not limited to:
• the services you use or processing your orders; • requests or questions you submit to us via online forms, email, or otherwise; • your participation in lottery games, contests, or survey via Online Services; • any reviews that you submit about the services; • account registration and administration of your account; • uploads or posts in relation to the services; • requests for customer support and technical assistance.
The types of personal data we collect directly from you includes:
• email addresses; • name, surname, if you choose to provide them; • log-in credentials, if you create an account; • billing information, such as mailing/shipping address, credit or debit card credentials and etc.; • 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 account 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 our services. If your purchase to be provided to someone other than yourself (such as a gift recipient), we use all information you provide about the other person to fulfill the shipment.
When you use our Online Services, we collect certain information as described in this section. As discussed further below, we and our service providers may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
When you use our website, we collect and analyze information such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs) referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the website.
When you use the Company’s mobile application or software (“App”), we automatically receive certain information about the mobile phone, tablet, or computer used to access the App, including device identifiers, IP address, operating system, version, Internet service provider, browser type, domain name and other similar information, whether and when you update the App, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the App.
When you use Online Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and/or postal code associated with an IP address, city/state) from your computer or mobile device.
If you access Online Services through a third-party connection or log-in (e.g., through a social network like Facebook or Twitter), you may allow us to have access to and store certain information from your social network profile. This can include your name, gender, profile picture, your “likes” and check-ins, and your list of friends, depending on your settings on such services. If you do not wish to have this information shared, do not use a social networking connection to access Online Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. You may also have the option of posting your Online Services activities to social networking services when you access content through the Online Services (for example, you may post to Facebook that you enrolled in a class on the Online Services); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any social networking services you have enabled will be able to view such activity.
We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising.
3. How We Use Your Information
We or our service providers, use your information for various purposes depending on the types of information we have collected from and about you, in order to:
• complete a purchase or provide the Online Services you have requested, including invoicing and accounting; • respond to your request for information and provide you with more effective and efficient customer service; • provide you with updates and information about courses, classes in which you have enrolled; • contact you by email, postal mail, or phone regarding the Company’s and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you; • customize the advertising and content you see on the Online Services; • help us better understand your interests and needs, and improve the Online Services, including through research and reports, and test and create new products, features, and services; • secure our websites and applications, and resolve app crashes and other issues being reported; • comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; • establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.
For the purposes discussed in this Policy, we may combine the information that we collect through the Online Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.
We may aggregate and/or anonymize any information collected through the Online Services so that such information can no longer be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.
4. Cookies and Similar Technologies
To collect the information, we and our service providers use Internet server logs, cookies, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to:
recognize your computer;
store your preferences and settings;
understand the web pages of the Online Services you have visited;
enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests;
perform searches and analytics; and
assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with flash technologies are stored with your Adobe Flash Player files.
As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of flash technologies, including flash cookies and local storage objects, with the flash management tools available at Adobe's website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Online Services.
5. Online Analytics And Advertising
We may use third-party web analytics services (such as those of Google Analytics) on our Online Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The Online Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Online Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Third parties may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. These third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) may also serve tailored ads to you as you use the Internet and Internet-connected applications, and access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Online Services to assist in this activity.
We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Online Services by such non-affiliated third parties. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Please note that if you exercise the choices above, you will still see advertising when you use the Online Services, but it will not be tailored to you based on your online behavior over time.
6. Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.
7. How We Share And Disclose Your Information
The Company will share your information in the following ways:
Affiliates and Subsidiaries. We may share information we collect within the Company’s group of companies to deliver products and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.
Service Providers. We provide access to or share your information with third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.
Protection of the Company and Others. By using the Online Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary:
(a) for any legal proceedings; (b) to enforce our Terms of Service, this Policy, or other contracts with you, including investigation of potential violations thereof; (c) to respond to claims that any content violates the rights of third parties; (d) to respond to your requests for customer service; and/or (e) to protect the rights, property or personal safety of the Company, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
Public Forums. Certain features of our Online Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.
Aggregate/Anonymous Information. From time to time, we may share aggregate/anonymous information about use of the Online Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.
8. Retention of Your Information
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
9. How We Protect Your Information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Third Party Links and Features
The Online Services contain links to third-party websites such as social media sites, and also contain third-party plug-ins (such as the Facebook “like” button and Twitter “follow” button). If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third-parties.
11. Children's Privacy
The Online Services are for general audience and is not designed nor intended to collect personal data of persons under the age of 16 (Sixteen). Persons under the age of 16 (Sixteen) should not provide any personal data via the Online Services. We ask that parents supervise their children while online.
12. 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. You may 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.
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 courses, classes in which you are enrolled.
The competent authority in Cyprus for the enforcement of personal data protection legislation is:
The Office of the Commissioner for the protection of personal data Address: Iasonos 1, 1082 Nicosia Cyprus or P.O.Box 23378, 1682 Nicosia Cyprus Telephone: +357 22818456 Fax: +357 22304565 Email: commissioner@dataprotection.gov.cy
You also have a right to lodge a complaint with the supervisory authority, The Office of the Commissioner for the protection of personal data, however we would appreciate the chance to deal with your concerns before you approach the supervisory authority.
13. Legal Bases for Use of Your Information
The legal bases for using your information as set out in this 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 Online 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 Online 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 Online Services); • where we are required to process information in accordance with an EU Member State legal obligation; • where we have your consent, in accordance with applicable law.
14. Changes to our Privacy Policy
We reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Online Services, or advances in technology. We will make the revised Policy accessible through the Online Services, so you should review the Policy periodically. You can know if the 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 Online Services, you are confirming that you have read and understood the latest version of this Policy.
If this Policy or any part of it should be determined to be illegal, invalid or otherwise unenforceable under the laws of any country in which this Policy is intended to be effective, then to the extent that it is determined to be illegal, invalid or unenforceable, it shall in that country be treated as severed and deleted from this Policy and the remaining terms of this Policy shall survive and remain in full force and effect and continue to be binding and enforceable in that country.
We are not be responsible for any breach of this Policy caused by circumstances beyond its reasonable control.
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