Privacy Policy


Last updated: May 29, 2024

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account
means a unique account created for You to access our Service or parts of our Service.

Affiliate

means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Business
for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal
information, that does business in the State of California.

CCPA and/or CPRA

refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

Company
(referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Faceted Fitness LLC, 423 Archer Street, Youngsville, La 70592.

For the purpose of the GDPR, the Company is the Data Controller.

Consumer

for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies
are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country
refers to: Louisiana, United States

Data Controller

for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device
means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Do Not Track

(DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Facebook Fan Page

is a public profile named Faceted Fitness specifically created by the Company on the Facebook social network, accessible from

https://www.facebook.com/facetedfitness

GDPR
refers to EU General Data Protection Regulation.

Personal Data

is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number,
location data, online identifier or to one or more factors specific to the
physical, physiological, genetic, mental, economic, cultural or social
identity.

For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable
of being associated with, or could reasonably be linked, directly or
indirectly, with You.

Service
refers to the Website.

Service Provider

means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service
Providers are considered Data Processors.

Third-party Social Media Service

refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data

refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website
refers to Faceted Fitness LLC, accessible from https://www.facetedfitness.com/

You
means the individual accessing or using the Service, or the company, or other
legal entity on behalf of which such individual is accessing or using the
Service, as applicable.

Under GDPR, You can be referred to as the
Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with
certain personally identifiable information that can be used to contact or
identify You. Personally identifiable information may include, but is not
limited to:

Email address

First name and last name

Phone number

Address, State, Province, ZIP/Postal code,
City

Usage Data

Usage Data

Usage Data is collected automatically when using the
Service.

Usage Data may include information such as Your Device's
Internet Protocol address (e.g. IP address), browser type, browser version, the
pages of our Service that You visit, the time and date of Your visit, the time
spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device,
We may collect certain information automatically, including, but not limited
to, the type of mobile device You use, Your mobile device unique ID, the IP
address of Your mobile device, Your mobile operating system, the type of mobile
Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends
whenever You visit our Service or when You access the Service by or through a
mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to
use the Service through the following Third-party Social Media Services:

·       

Google

·       

Facebook

·       

Twitter

·       

LinkedIn

If You decide to register through or otherwise grant us
access to a Third-Party Social Media Service, We may collect Personal data that
is already associated with Your Third-Party Social Media Service's account,
such as Your name, Your email address, Your activities or Your contact list
associated with that account.

You may also have the option of sharing additional
information with the Company through Your Third-Party Social Media Service's
account. If You choose to provide such information and Personal Data, during
registration or otherwise, You are giving the Company permission to use, share,
and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track
the activity on Our Service and store certain information. Tracking
technologies used are beacons, tags, and scripts to collect and track
information and to improve and analyze Our Service. The technologies We use may
include:

·        Cookies or Browser Cookies.

A cookie is a small file placed on Your Device. You can
instruct Your browser to refuse all Cookies or to indicate when a Cookie is
being sent. However, if You do not accept Cookies, You may not be able to use
some parts of our Service. Unless you have adjusted Your browser setting so
that it will refuse Cookies, our Service may use Cookies.

·        Web Beacons.

Certain sections of our Service and our emails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel
tags, and single-pixel gifs) that permit the Company, for example, to count
users who have visited those pages or opened an email and for other related
website statistics (for example, recording the popularity of a certain section
and verifying system and server integrity).

Cookies can be "Persistent" or "Session"
Cookies. Persistent Cookies remain on Your personal computer or mobile device
when You go offline, while Session Cookies are deleted as soon as You close
Your web browser. You can learn more about cookies on

TermsFeed website

article.

We use both Session and Persistent Cookies for the purposes
set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to
provide You with services available through the Website and to enable You to
use some of its features. They help to authenticate users and prevent
fraudulent use of user accounts. Without these Cookies, the services that You
have asked for cannot be provided, and We only use these Cookies to provide You
with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users
have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember
choices You make when You use the Website, such as remembering your login
details or language preference. The purpose of these Cookies is to provide You
with a more personal experience and to avoid You having to re-enter your
preferences every time You use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track
information about traffic to the Website and how users use the Website. The
information gathered via these Cookies may directly or indirectly identify you
as an individual visitor. This is because the information collected is
typically linked to a pseudonymous identifier associated with the device you
use to access the Website. We may also use these Cookies to test new pages,
features or new functionality of the Website to see how our users react to
them.

For more information about the cookies we use and your
choices regarding cookies, please visit our Cookies Policy or the Cookies
section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following
purposes:

·        To provide and maintain our Service

, including to monitor the usage of our
Service.

·        To manage Your Account:

to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of
the Service that are available to You as a registered user.

·        For the performance of a contract:

the development, compliance and undertaking of
the purchase contract for the products, items or services You have purchased or
of any other contract with Us through the Service.

·        To contact You:

To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile application's
push notifications regarding updates or informative communications related to
the functionalities, products or contracted services, including the security
updates, when necessary or reasonable for their implementation.

·        To provide You

with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you
have already purchased or enquired about unless You have opted not to receive
such information.

·        To manage Your requests:

To attend and manage Your requests to Us.

·        To deliver targeted advertising to You

: We may use Your information to develop
and display content and advertising (and work with third-party vendors who do
so) tailored to Your interests and/or location and to measure its
effectiveness.

·        For business transfers:

We may use Your information to evaluate or conduct a
merger, divestiture, restructuring, reorganization, dissolution, or other sale
or transfer of some or all of Our assets, whether as a going concern or as part
of bankruptcy, liquidation, or similar proceeding, in which Personal Data held
by Us about our Service users is among the assets transferred.

·        For other purposes

: We may use Your information for other purposes, such as data
analysis, identifying usage trends, determining the effectiveness of our
promotional campaigns and to evaluate and improve our Service, products,
services, marketing and your experience.

We may share Your personal information in the following
situations:

·        With Service Providers:

We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to advertise on third
party websites to You after You visited our Service, for payment processing, to
contact You.

·        For business transfers:

We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets,
financing, or acquisition of all or a portion of Our business to another
company.

·        With Affiliates:

We may share Your information with Our affiliates, in which
case we will require those affiliates to honor this Privacy Policy. Affiliates
include Our parent company and any other subsidiaries, joint venture partners
or other companies that We control or that are under common control with Us.

·        With business partners:

We may share Your information with Our business partners
to offer You certain products, services or promotions.

·        With other users:

when You share personal information or otherwise interact in
the public areas with other users, such information may be viewed by all users
and may be publicly distributed outside. If You interact with other users or
register through a Third-Party Social Media Service, Your contacts on the
Third-Party Social Media Service may see Your name, profile, pictures and
description of Your activity. Similarly, other users will be able to view
descriptions of Your activity, communicate with You and view Your profile.

·        With Your consent

: We may disclose Your personal information for any other purpose
with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long
as is necessary for the purposes set out in this Privacy Policy. We will retain
and use Your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply with
applicable laws), resolve disputes, and enforce our legal agreements and
policies.

The Company will also retain Usage Data for internal
analysis purposes. Usage Data is generally retained for a shorter period of
time, except when this data is used to strengthen the security or to improve
the functionality of Our Service, or We are legally obligated to retain this
data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at
the Company's operating offices and in any other places where the parties
involved in the processing are located. It means that this information may be
transferred to — and maintained on — computers located outside of Your state,
province, country or other governmental jurisdiction where the data protection
laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your
submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to
ensure that Your data is treated securely and in accordance with this Privacy
Policy and no transfer of Your Personal Data will take place to an organization
or a country unless there are adequate controls in place including the security
of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in
deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain
information about You from within the Service.

You may update, amend, or delete Your information at any
time by signing in to Your Account, if you have one, and visiting the account
settings section that allows you to manage Your personal information. You may
also contact Us to request access to, correct, or delete any personal
information that You have provided to Us.

Please note, however, that We may need to retain certain
information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset
sale, Your Personal Data may be transferred. We will provide notice before Your
Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to
disclose Your Personal Data if required to do so by law or in response to valid
requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith
belief that such action is necessary to:

·       

Comply with a legal obligation

·       

Protect and defend the rights or property of the
Company

·       

Prevent or investigate possible wrongdoing in
connection with the Service

·       

Protect the personal safety of Users of the
Service or the public

·       

Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but
remember that no method of transmission over the Internet, or method of
electronic storage is 100% secure. While We strive to use commercially
acceptable means to protect Your Personal Data, We cannot guarantee its
absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your
Personal Data. These third-party vendors collect, store, use, process and
transfer information about Your activity on Our Service in accordance with
their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and
analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service
offered by Google that tracks and reports website traffic. Google uses the data
collected to track and monitor the use of our Service. This data is shared with
other Google services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network.

You can opt-out of having made your
activity on the Service available to Google Analytics by installing the Google
Analytics opt-out browser add-on. The add-on prevents the Google Analytics
JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google
Analytics about visits activity.

For more information on the privacy practices
of Google, please visit the Google Privacy & Terms web page:

https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with
newsletters, marketing or promotional materials and other information that may
be of interest to You. You may opt-out of receiving any, or all, of these
communications from Us by following the unsubscribe link or instructions
provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and
send emails to You.

Mailchimp

Mailchimp is an email marketing sending
service provided by The Rocket Science Group LLC. For more information on the
privacy practices of Mailchimp, please visit their Privacy policy:

https://mailchimp.com/legal/privacy/ ConvertKit

Their Privacy Policy can be viewed at

https://convertkit.com/privacy GoHighLevel

Their Privacy Policy can be viewed at

https://www.gohighlevel.com/privacy-policy Wordpress

Their Privacy Policy can be viewed at https://wordpress.org/about/privacy/

Payments

We may provide paid products and/or services within the
Service. In that case, we may use third-party services for payment processing
(e.g. payment processors).

We will not store or collect Your payment card details. That
information is provided directly to Our third-party payment processors whose
use of Your personal information is governed by their Privacy Policy. These
payment processors 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 payment information.

Stripe

Their Privacy Policy can be viewed at

https://stripe.com/us/privacy

Behavioral Remarketing

The Company uses remarketing services to advertise to You
after You accessed or visited our Service. We and Our third-party vendors use
cookies and non-cookie technologies to help Us recognize Your Device and
understand how You use our Service so that We can improve our Service to
reflect Your interests and serve You advertisements that are likely to be of
more interest to You.

These third-party vendors collect, store, use, process and
transfer information about Your activity on Our Service in accordance with
their Privacy Policies and to enable Us to:

·       

Measure and analyze traffic and browsing
activity on Our Service

·       

Show advertisements for our products and/or
services to You on third-party websites or apps

·       

Measure and analyze the performance of Our
advertising campaigns

Some of these third-party vendors may use non-cookie
technologies that may not be impacted by browser settings that block cookies.
Your browser may not permit You to block such technologies. You can use the
following third-party tools to decline the collection and use of information
for the purpose of serving You interest-based advertising:

·       

The NAI's opt-out platform:

http://www.networkadvertising.org/choices/ ·       

The EDAA's opt-out platform

http://www.youronlinechoices.com/ ·       

The DAA's opt-out platform:

http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling
privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt
Out of Ads Personalization (Android). See Your mobile device Help system for
more information.

We may share information, such as hashed email addresses (if
available) or other online identifiers collected on Our Service with these
third-party vendors. This allows Our third-party vendors to recognize and
deliver You ads across devices and browsers. To read more about the
technologies used by these third-party vendors and their cross-device
capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is
provided by Google Inc.

You can opt-out of Google Analytics for
Display Advertising and customize the Google Display Network ads by visiting
the Google Ads Settings page:

http://www.google.com/settings/ads

Google also recommends installing the
Google Analytics Opt-out Browser Add-on -

https://tools.google.com/dlpage/gaoptout


- for your web browser. Google Analytics Opt-out Browser Add-on provides
visitors with the ability to prevent their data from being collected and used
by Google Analytics.

For more information on the privacy practices
of Google, please visit the Google Privacy & Terms web page:

https://policies.google.com/privacy

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

·        Consent:


You have given Your consent for processing Personal Data for one or more
specific purposes.

·        Performance of a contract:

Provision of Personal Data is necessary for the performance
of an agreement with You and/or for any pre-contractual obligations thereof.

·        Legal obligations:

Processing Personal Data is necessary for compliance with a
legal obligation to which the Company is subject.

·        Vital interests:

Processing Personal Data is necessary in order to protect Your
vital interests or of another natural person.

·        Public interests:

Processing Personal Data is related to a task that is carried
out in the public interest or in the exercise of official authority vested in
the Company.

·        Legitimate interests:

Processing Personal Data is necessary for the purposes of the
legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the
specific legal basis that applies to the processing, and in particular whether
the provision of Personal Data is a statutory or contractual requirement, or a
requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of
Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if
You are within the EU, to:

·        Request access to Your Personal Data.

The right to access, update or delete the
information We have on You. Whenever made possible, you can access, update or
request deletion of Your Personal Data directly within Your account settings
section. If you are unable to perform these actions yourself, please contact Us
to assist You. This also enables You to receive a copy of the Personal Data We
hold about You.

·        Request correction of the Personal Data that We hold about You.

You have the right
to have any incomplete or inaccurate information We hold about You corrected.

·        Object to processing of Your Personal Data.

This right exists where We are relying on
a legitimate interest as the legal basis for Our processing and there is
something about Your particular situation, which makes You want to object to
our processing of Your Personal Data on this ground. You also have the right to
object where We are processing Your Personal Data for direct marketing
purposes.

·        Request erasure of Your Personal Data.

You have the right to ask Us to delete or
remove Personal Data when there is no good reason for Us to continue processing
it.

·        Request the transfer of Your Personal Data.

We will provide to You, or to a
third-party You have chosen, Your Personal Data in a structured, commonly used,
machine-readable format. Please note that this right only applies to automated
information which You initially provided consent for Us to use or where We used
the information to perform a contract with You.

·        Withdraw Your consent.

You have the right to withdraw Your consent on using your
Personal Data. If You withdraw Your consent, We may not be able to provide You
with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification,
cancellation and opposition by contacting Us. Please note that we may ask You
to verify Your identity before responding to such requests. If You make a
request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection
Authority about Our collection and use of Your Personal Data. For more
information, if You are in the European Economic Area (EEA), please contact
Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data
collected while using the Service. As operator of the Facebook Fan Page

https://www.facebook.com/facetedfitness

,
the Company and the operator of the social network Facebook are Joint
Controllers.

The Company has entered into agreements with Facebook that
define the terms for use of the Facebook Fan Page, among other things. These
terms are mostly based on the Facebook Terms of Service:

https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy

https://www.facebook.com/policy.php


for more information about how Facebook manages Personal data or contact
Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601
Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the
operation of the Facebook Fan Page and on the basis of the GDPR, in order to
obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of
the user visiting Our Facebook Fan Page. Each Cookie contains a unique
identifier code and remains active for a period of two years, except when it is
deleted before the end of this period.

Facebook receives, records and processes the information
stored in the Cookie, especially when the user visits the Facebook services,
services that are provided by other members of the Facebook Fan Page and
services by other companies that use Facebook services.

For more information on the privacy practices of Facebook,
please visit Facebook Privacy Policy here:

https://www.facebook.com/privacy/explanation

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents
supplements the information contained in Our Privacy Policy and it applies
solely to all visitors, users, and others who reside in the State of
California.

Categories of Personal Information Collected

We collect information that identifies, relates to,
describes, references, is capable of being associated with, or could reasonably
be linked, directly or indirectly, with a particular Consumer or Device. The
following is a list of categories of personal information which we may collect
or may have been collected from California residents within the last twelve
(12) months.

Please note that the categories and examples provided in the
list below are those defined in the CCPA/CPRA. This does not mean that all
examples of that category of personal information were in fact collected by Us,
but reflects our good faith belief to the best of Our knowledge that some of
that information from the applicable category may be and may have been
collected. For example, certain categories of personal information would only
be collected if You provided such personal information directly to Us.

Category A: Identifiers.

Examples: A real name, alias, postal
address, unique personal identifier, online identifier, Internet Protocol
address, email address, account name, driver's license number, passport number,
or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social
Security number, physical characteristics or description, address, telephone
number, passport number, driver's license or state identification card number,
insurance policy number, education, employment, employment history, bank
account number, credit card number, debit card number, or any other financial
information, medical information, or health insurance information. Some
personal information included in this category may overlap with other
categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race,
color, ancestry, national origin, citizenship, religion or creed, marital
status, medical condition, physical or mental disability, sex (including
gender, gender identity, gender expression, pregnancy or childbirth and related
medical conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products
or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological,
behavioral, and biological characteristics, or activity patterns used to
extract a template or other identifier or identifying information, such as,
fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,
gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or
advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Audio, electronic, visual,
thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or
performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly
related to a student maintained by an educational institution or party acting
on its behalf, such as grades, transcripts, class lists, student schedules,
student identification codes, student financial information, or student
disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Category L: Sensitive personal information.

Examples: Account login and password
information, geolocation data.

Collected: Yes.

Under CCPA/CPRA, personal information does not include:

·       

Publicly available information from government
records

·       

Deidentified or aggregated consumer information

·       

Information excluded from the CCPA/CPRA's scope,
such as:

·       

Health or medical information covered by the
Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the
California Confidentiality of Medical Information Act (CMIA) or clinical trial
data

·       

Personal Information covered by certain
sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA),
the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy
Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed
above from the following categories of sources:

·        Directly from You

. For example, from the forms You complete on our Service,
preferences You express or provide through our Service, or from Your purchases
on our Service.

·        Indirectly from You

. For example, from observing Your activity on our Service.

·        Automatically from You

. For example, through cookies We or our Service Providers set on
Your Device as You navigate through our Service.

·        From Service Providers

. For example, third-party vendors to monitor and analyze
the use of our Service, third-party vendors to deliver targeted advertising to
You, third-party vendors for payment processing, or other third-party vendors
that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for
"business purposes" or "commercial purposes" (as defined
under the CCPA/CPRA), which may include the following examples:

·       

To operate our Service and provide You with Our
Service.

·       

To provide You with support and to respond to
Your inquiries, including to investigate and address Your concerns and monitor
and improve our Service.

·       

To fulfill or meet the reason You provided the
information. For example, if You share Your contact information to ask a
question about our Service, We will use that personal information to respond to
Your inquiry. If You provide Your personal information to purchase a product or
service, We will use that information to process Your payment and facilitate
delivery.

·       

To respond to law enforcement requests and as
required by applicable law, court order, or governmental regulations.

·       

As described to You when collecting Your
personal information or as otherwise set forth in the CCPA/CPRA.

·       

For internal administrative and auditing
purposes.

·       

To detect security incidents and protect against
malicious, deceptive, fraudulent or illegal activity, including, when
necessary, to prosecute those responsible for such activities.

·       

Other one-time uses.

Please note that the examples provided above are
illustrative and not intended to be exhaustive. For more details on how we use
this information, please refer to the "Use of Your Personal Data"
section.

If We decide to collect additional categories of personal
information or use the personal information We collected for materially
different, unrelated, or incompatible purposes, We will update this Privacy
Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the
last twelve (12) months the following categories of personal information for
business or commercial purposes:

·       

Category A: Identifiers

·       

Category B: Personal information categories
listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·       

Category D: Commercial information

·       

Category F: Internet or other similar network
activity

Please note that the categories listed above are those
defined in the CCPA/CPRA. This does not mean that all examples of that category
of personal information were in fact disclosed, but reflects our good faith
belief to the best of our knowledge that some of that information from the
applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose
or a commercial purpose, We enter a contract that describes the purpose and
requires the recipient to both keep that personal information confidential and
not use it for any purpose except performing the contract.

Share of Personal Information

We may share, and have shared in the last twelve (12)
months, Your personal information identified in the above categories with the
following categories of third parties:

·       

Service Providers

·       

Payment processors

·       

Our affiliates

·       

Our business partners

·       

Third party vendors to whom You or Your agents
authorize Us to disclose Your personal information in connection with products
or services We provide to You

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and
"sale" mean selling, renting, releasing, disclosing, disseminating,
making available, transferring, or otherwise communicating orally, in writing,
or by electronic or other means, a Consumer's personal information by the
Business to a third party for valuable consideration. This means that We may
have received some kind of benefit in return for sharing personal information,
but not necessarily a monetary benefit.

We do not sell personal information as the term sell is
commonly understood. We do allow Service Providers to use Your personal
information for the business purposes described in Our Privacy Policy, for
activities such as advertising, marketing, and analytics, and these may be
deemed a sale under CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months
the following categories of personal information:

·       

Category A: Identifiers

·       

Category B: Personal information categories
listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·       

Category D: Commercial information

·       

Category F: Internet or other similar network
activity

Please note that the categories listed above are those
defined in the CCPA/CPRA. This does not mean that all examples of that category
of personal information were in fact sold, but reflects our good faith belief
to the best of Our knowledge that some of that information from the applicable
category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors
under the age of 16 through our Service, although certain third party websites
that we link to may do so. These third-party websites have their own terms of
use and privacy policies and We encourage parents and legal guardians to
monitor their children's Internet usage and instruct their children to never
provide information on other websites without their permission.

We do not sell the personal information of Consumers We
actually know are less than 16 years of age, unless We receive affirmative
authorization (the "right to opt-in") from either the Consumer who is
between 13 and 16 years of age, or the parent or guardian of a Consumer less
than 13 years of age. Consumers who opt-in to the sale of personal information
may opt-out of future sales at any time. To exercise the right to opt-out, You
(or Your authorized representative) may submit a request to Us by contacting
Us.

If You have reason to believe that a child under the age of
13 (or 16) has provided Us with personal information, please contact Us with
sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific
rights regarding their personal information. If You are a resident of
California, You have the following rights:

·        The right to notice.

You have the right to be notified which categories of Personal
Data are being collected and the purposes for which the Personal Data is being
used.

·        The right to know/access.

Under CCPA/CPRA, You have the right to request that We
disclose information to You about Our collection, use, sale, disclosure for
business purposes and share of personal information. Once We receive and
confirm Your request, We will disclose to You:

·       

The categories of personal information We
collected about You

·       

The categories of sources for the personal
information We collected about You

·       

Our business or commercial purposes for
collecting or selling that personal information

·       

The categories of third parties with whom We
share that personal information

·       

The specific pieces of personal information We
collected about You

·       

If we sold Your personal information or
disclosed Your personal information for a business purpose, We will disclose to
You:

·       

The categories of personal information
categories sold

·       

The categories of personal information
categories disclosed

·        The right to say no to the sale or sharing of Personal Data (opt-out).

You have the
right to direct Us to not sell Your personal information. To submit an opt-out
request, please see the "Do Not Sell My Personal Information" section
or contact Us.

·        The right to correct Personal Data.

You have the right to correct or rectify any
inaccurate personal information about You that We collected. Once We receive
and confirm Your request, We will use commercially reasonable efforts to
correct (and direct our Service Providers to correct) Your personal
information, unless an exception applies.

·        The right to limit use and disclosure of sensitive Personal Data.

You have the right
to request to limit the use or disclosure of certain sensitive personal
information We collected about You, unless an exception applies. To submit,
please see the "Limit the Use or Disclosure of My Sensitive Personal
Information" section or contact Us.

·        The right to delete Personal Data.

You have the right to request the deletion of Your
Personal Data under certain circumstances, subject to certain exceptions. Once
We receive and confirm Your request, We will delete (and direct Our Service
Providers to delete) Your personal information from our records, unless an
exception applies. We may deny Your deletion request if retaining the
information is necessary for Us or Our Service Providers to:

·       

Complete the transaction for which We collected
the personal information, provide a good or service that You requested, take
actions reasonably anticipated within the context of our ongoing business
relationship with You, or otherwise perform our contract with You.

·       

Detect security incidents, protect against
malicious, deceptive, fraudulent, or illegal activity, or prosecute those
responsible for such activities.

·       

Debug products to identify and repair errors
that impair existing intended functionality.

·       

Exercise free speech, ensure the right of
another consumer to exercise their free speech rights, or exercise another
right provided for by law.

·       

Comply with the California Electronic
Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

·       

Engage in public or peer-reviewed scientific,
historical, or statistical research in the public interest that adheres to all
other applicable ethics and privacy laws, when the information's deletion may
likely render impossible or seriously impair the research's achievement, if You
previously provided informed consent.

·       

Enable solely internal uses that are reasonably
aligned with consumer expectations based on Your relationship with Us.

·       

Comply with a legal obligation.

·       

Make other internal and lawful uses of that
information that are compatible with the context in which You provided it.

·        The right not to be discriminated against.

You have the right not to be discriminated
against for exercising any of Your consumer's rights, including by:

·       

Denying goods or services to You

·       

Charging different prices or rates for goods or
services, including the use of discounts or other benefits or imposing
penalties

·       

Providing a different level or quality of goods
or services to You

·       

Suggesting that You will receive a different
price or rate for goods or services or a different level or quality of goods or
services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell My Personal
Information" section and "Limit the Use or Disclosure of My Sensitive
Personal Information" section for more information on how to opt out and
limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under
the CCPA/CPRA, and if You are a California resident, You can contact Us:

·       

By email: [email protected]

Only You, or a person registered with the California
Secretary of State that You authorize to act on Your behalf, may make a
verifiable request related to Your personal information.

Your request to Us must:

·       

Provide sufficient information that allows Us to
reasonably verify You are the person about whom We collected personal
information or an authorized representative

·       

Describe Your request with sufficient detail
that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the
required information if We cannot:

·       

Verify Your identity or authority to make the
request

·       

And confirm that the personal information
relates to You

We will disclose and deliver the required information free
of charge within 45 days of receiving Your verifiable request. The time period
to provide the required information may be extended once by an additional 45
days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month
period preceding the verifiable request's receipt.

For data portability requests, We will select a format to
provide Your personal information that is readily usable and should allow You
to transmit the information from one entity to another entity without
hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, "sell" and
"sale" mean selling, renting, releasing, disclosing, disseminating,
making available, transferring, or otherwise communicating orally, in writing,
or by electronic or other means, a Consumer's personal information by the
Business to a third party for valuable consideration. This means that We may
have received some kind of benefit in return for sharing personal information,
but not necessarily a monetary benefit.

We do not sell personal information as the term sell is
commonly understood. We do allow Service Providers to use Your personal
information for the business purposes described in Our Privacy Policy, for
activities such as advertising, marketing, and analytics, and these may be
deemed a sale under CCPA/CPRA.

You have the right to opt-out of the sale of Your personal
information. Once We receive and confirm a verifiable consumer request from
You, we will stop selling Your personal information. To exercise Your right to
opt-out, please contact Us.

The Service Providers we partner with (for example, our
analytics or advertising partners) may use technology on the Service that sells
personal information as defined by the CCPA/CPRA law. If you wish to opt out of
the use of Your personal information for interest-based advertising purposes
and these potential sales as defined under CCPA/CPRA law, you may do so by
following the instructions below.

Please note that any opt out is specific to the browser You
use. You may need to opt out on every browser that You use.

Website

If applicable, click "Privacy Preferences",
"Update Privacy Preferences" or "Do Not Sell My Personal
Information" buttons listed on the Service to review Your privacy
preferences and opt out of cookies and other technologies that We may use.
Please note that You will need to opt out from each browser that You use to
access the Service.

Additionally, You can opt out of receiving ads that are
personalized as served by our Service Providers by following our instructions
presented on the Service:

·       

The NAI's opt-out platform:

http://www.networkadvertising.org/choices/ ·       

The EDAA's opt-out platform

http://www.youronlinechoices.com/ ·       

The DAA's opt-out platform:

http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is
unique to the browser You use to opt out. If you change browsers or delete the
cookies saved by Your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of
the use of information about the apps You use in order to serve You ads that
are targeted to Your interests:

·       

"Opt out of Interest-Based Ads" or
"Opt out of Ads Personalization" on Android devices

·       

"Limit Ad Tracking" on iOS devices

You can also stop the collection of location information
from Your mobile device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to
limit the use and disclosure of Your sensitive personal information to that use
which is necessary to perform the services or provide the goods reasonably
expected by an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information
in ways that are necessary to provide the Service. For more information on how
We use Your personal information, please see the "Use of Your Personal
Data" section or contact us.

"Do Not Track" Policy as Required by California
Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your
browsing activities. If You are visiting such websites, You can set Your
preferences in Your web browser to inform websites that You do not want to be
tracked. You can enable or disable DNT by visiting the preferences or settings
page of Your web browser.

Your California Privacy Rights (California's Shine the Light
law)

Under California Civil Code Section 1798 (California's Shine
the Light law), California residents with an established business relationship
with us can request information once a year about sharing their Personal Data
with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the
California Shine the Light law, and if You are a California resident, You can
contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California
Business and Professions Code Section 22581)

California Business and Professions Code Section 22581
allows California residents under the age of 18 who are registered users of
online sites, services or applications to request and obtain removal of content
or information they have publicly posted.

To request removal of such data, and if You are a California
resident, You can contact Us using the contact information provided below, and
include the email address associated with Your account.

Be aware that Your request does not guarantee complete or
comprehensive removal of content or information posted online and that the law
may not permit or require removal in certain circumstances.

Children's Privacy

Our Service does not address anyone under the age of 13. We
do not knowingly collect personally identifiable information from anyone under
the age of 13. If You are a parent or guardian and You are aware that Your
child has provided Us with Personal Data, please contact Us. If We become aware
that We have collected Personal Data from anyone under the age of 13 without
verification of parental consent, We take steps to remove that information from
Our servers.

If We need to rely on consent as a legal basis for
processing Your information and Your country requires consent from a parent, We
may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not
operated by Us. If You click on a third party link, You will be directed to
that third party's site. We strongly advise You to review the Privacy Policy of
every site You visit.

We have no control over and assume no responsibility for the
content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will
notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on
Our Service, prior to the change becoming effective and update the "Last
updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically
for any changes. Changes to this Privacy Policy are effective when they are
posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can
contact us:

·       

By email: [email protected]