We may collect personal information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, subscribe to our newsletter, and in connection with accessing our Services. Users may be asked for, as appropriate, email address. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal information, except that it may prevent them from engaging in certain Site related activities or the Services. We do not collect “sensitive” or “special” categories of personal information.
Account information – Users need to create an online account to enroll in our online classes and other Services and to make payment. You will need to provide your name and email address to create the account. Payment is to be made through your account. You will also be asked to provide a unique password when you set up the account.
When you contact us — When you contact us, whether by email, by phone or via the contact link on the Site, we will need to collect your name, phone number, email address and, if relevant, access your account to respond to your inquiry or request.
Information collected automatically
We may automatically collect certain non-personal information about Users whenever they interact with our Site. Non-personal information may include information regarding your device, such as IP address ((or media access control (“MAC”) address, as applicable), the browser you use, operating system and the Internet service providers utilized and other similar information. We also automatically collect information about your use of the Site and Services, such as web requests, number of clicks, domain names, pages viewed and the amount of time spent on particular pages, the date and time of use of Services, purchase history and other interactions
We reserve the right and discretion to create, use and disclose anonymous and aggregate information, i.e., information about specific individuals or groups of individuals from which personal identifiers have been removed and specific individuals cannot be identified.
Cookies and other tracking technologies —
Our Site may use ‘cookies’ to enhance the User experience. Cookies are small data files that are commonly stored on your device when you browse and use websites and online services.
- Strictly Necessary Cookies: These cookies are strictly necessary to provide the Site and Services. For example, they are used to authenticate and identify Users.
- Performance and Functionality Cookies: These cookies provide statistical information on site usage, such as web analytics. They also help us to personalize and enhance your online experience.
You can set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. However, if you set your browser to disable all cookies, some features of the Services may not function properly. To delete or opt out of cookies, please see below under “Your Choices.” However, if your browser no longer accepts cookies, some parts of the Site may not function properly.
Do Not Track — Some web browsers and devices allow you to broadcast a preference that your activities online not be “tracked”. At this time, our Site does not honor “do not track” signals
Apps – If you use the Strala app on a mobile device, tablet, or streaming media device, we may collect a resettable device identifier from your device. Resettable device identifiers (also known as advertising identifiers) are similar to cookies and are found on many mobile devices and tablets (for example, the “Identifier for Advertisers” (or IDFA) on Apple iOS devices and the “Google Advertising ID” on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant and for analytics and optimization purposes. However, we currently do not use these identifiers to serve advertising on our app.
How we use collected information
We may collect and use Users’ personal information for the following purposes:
- With your consent
- To provide the requested Services
We use your personal information to provide you with the Services or purchases you requested.
- To improve customer service
Personal information you provide helps us respond to your customer service requests and support needs more efficiently.
- To personalize user experience
We may use personal information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
- To send you messages
We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product, service or promotional information, etc. If at any time the User would like to unsubscribe from receiving these communications, we include detailed unsubscribe instructions at the bottom of each email or User may contact us as described below. Please note, however, you cannot opt out of receiving communications concerning, for example, a class or other Service you have ordered or if there is a problem with your payment.
How we may share your information
We may disclose your personal information for the following categories of business purposes:
- To our third-party service providers who provide services such as information technology and related infrastructure provisioning, messaging and voice services, email delivery, data analysis, marketing analysis, auditing, and other services. These service providers are legally obligated to ensure the confidentiality of Personal Information and implement appropriate security measures.
- We use Teachable.com and Uscreen.tv as our platforms to host and make accessible our online classes. These third parties collect certain personal information about our Users to enable Strala to use their platforms. Their use of personal information it may collect is governed by their Privacy Policies: https://teachable.com/privacy-policy and https://www.uscreen.tv/privacy-policy/.
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).
- As we believe to be necessary or appropriate: under applicable law; to comply with legal process; to respond to requests from public and government authorities; to enforce our terms and conditions; to protect our operations; to protect our rights, privacy, safety, or property, and/or that of you or others; and to allow us to pursue available remedies or limit the damages that we may sustain.
- Accessing our online classes and other Services may be enabled on third party video platforms (e.g., AppleTV, Roku). Users may need to separately register for these platforms to access our Services. Any collection of your personal information to use these platforms is subject to their privacy policies. We are not responsible for these platform’s privacy policies. Strala does not otherwise disclose your personal information to these platforms.
Please note that we do not sell, trade, or rent Users’ personal information to others. We may share generic aggregated demographic information not linked to any personal information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. However, no data transmission through the Internet or via mobile devices, or even the physical transfer of information, can be guaranteed to be completely secure. We cannot fully eliminate all security risks associated with your transmitting personal information to us. We do not ensure or warrant the security of any data or information you transmit to us, and you do so at your own risk.
Please do not provide your password to another person. We cannot be responsible for a data breach or other incident if a password is used by unauthorized persons.
We will keep your account information as long as needed to meet the purposes for which it was collected, to provide the services you requested, or as otherwise may be required by law.
We strive to provide you with choices regarding the personal information you provide to us. We have created the following mechanisms to provide you choices and control over your information.
Your account – We will update or correct your information as needed when notified by you. If you would like to request access to your personal information, request to verify your personal information, identify any inaccuracy in your personal information, or change your personal information in any way, please contact us at email@example.com. Users in the United Kingdom or European Economic Area have the additional rights to request erasure of, restrict the processing of, or object to certain processing of their personal information, as well as to data portability, as described below.
Other uses — We will not collect, use, or disclose your personal information in any ways or for any purposes that are materially different from those set forth herein. However, if we wish to do so in the future, we will obtain your consent first, and offer you the choice to opt-out of such proposed collection, use, or disclosure.
Promotional messages – You can opt-out of our marketing or promotional email communications by using the “Unsubscribe” feature at the bottom of each email from us or by requesting to opt out by emailing us at firstname.lastname@example.org. Please note that you cannot opt out of receiving transactions communications from us regarding Services you request or use or other transactional or administrative issues.
Cookies — You have the ability to opt-out of certain cookies by going to the Cookie Preferences of your browser. Also, you can find out more information about how to change your browser cookie settings at www.allaboutcookies.org. If you choose to disable cookies, please note that you may not be able to sign in or use some of the interactive features offered on our Site or Services.
Google Analytics – We may use Google Analytics to help us manage and improve the Sites and Services. Google provides a Browser Add-On that allows you to opt-out by downloading and installing the add-on for your web browser. This is available here https://tools.google.com/dlpage/gaoptout.
Residents of the European Economic Area (EEA) or UK may have additional choices and rights regarding their personal information, as described below.
Located in the United States
Strala, the Site and the Services are located in the United States and governed by US law. If you are outside the United States when you visit Site, access the Services or engage in communications with us via mail, e-mail or telephone, please be aware that your personal information will be transferred to, stored and processed in the United States where our servers are located. Any information you provide to us, or that we collect through your use of the Site and Services and will be stored, processed, and transferred within, or to, the United States. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country. Note that your personal information may be available to the US Government or its agencies under legal process in the United States.
Users in EEA and UK
The Legal Basis for Using EEA and UK Personal Information — For residents of the European Economic Area (EEA) and United Kingdom, we advise that your personal information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”). Our legal basis for collecting and using your personal information is to do so with your consent; where we need the personal information for performance of a contract or requested service, including to provide you with our newsletter, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collected your Personal Information with your consent, you may withdraw your consent at any time.
Our retention of your personal information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.
To the extent that we transfer personal information from the EEA or UK to a jurisdiction outside the EEA or UK that has not been adduced by the European Commission as providing adequate data protections (such as the United States), we will ensure that such Personal Information is safeguarded through appropriate contractual terms or other approved mechanisms.
Rights for EEA or UK Residents – In addition, if you are a resident of the EEA or UK, you have the right to:
- Find out if we use your personal information, to access your Personal Information, and receive copies of your personal information.
- Withdraw any express consent that you have provided to the processing of your personal information at any time without penalty.
- Access your personal information and have it corrected or amended if it is inaccurate or incomplete.
- Obtain a transferable copy of some of your personal information which can be transferred to another provider when the personal information was processed based on your consent.
- If you believe your personal information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your personal information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
- Request your personal information be deleted or restricted under certain circumstances. For example, if is using your personal information on the basis of your consent and has no other legal basis to use such, you may request your personal information be deleted when you withdraw your consent.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide personal information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal Information is required and if not, the consequences of not sharing your personal information with us.
Similarly, if we collect and use your personal information in reliance on our or a third party’s legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.
To withdraw consent or exercise these rights, please contact us via email at email@example.com.
If you are not satisfied with our response, or believe we are processing your personal information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State or United Kingdom. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
You must be 18 years or older to use our Site and access the Services. We do not knowingly collect or solicit information from children under the age of 13 (in the United States) or under 16 (in the EEA). If you are a parent or guardian of a child and believe he or she has disclosed personally identifiable information to us, please contact us at firstname.lastname@example.org so that we may take steps to remove that information and terminate the child’s account, if any.
Third party websites or platforms
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We also use a third-party platform to host our online classes. We do not control the content or links that appear on these sites or platform and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website or platform, including websites which have a link to our Site, is subject to that website’s or platform’s own terms and policies.
Last updated: June 1, 2020