Who We Are
Usage Data: Usage Data is 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).
Data Processors (or Service Provider): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively
Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data.
1. What information do we collect?
1.1 Personal Data Provided by User
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data. We collect certain data from you directly, like information you enter yourself, data about your participation in courses, and data from third-party platforms you connect with KOOATI. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect. When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:We collect personal information that you voluntarily provide to us when registering at the Website, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Website (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect can include the following:Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
|In order to use certain features (like enrolling in a course), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, phone number, occupation, skill interests, gender, race, ethnicity, government ID information, verification photo, age, and date of birth, and assign you a unique identifying number (“Account Data”).|
|Profile Data||You can also choose to provide profile information like a photo, headline, biography, language, website link, social media profiles, country, or other data. Your Profile Data will be publicly viewable by others.|
|Shared Content||Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a course page, asking or answering questions, sending messages to students or instructors, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.|
|Course Data||When you enroll in and take courses, we collect certain data including which courses, assignments and quizzes you’ve started and completed; your exchanges with instructors, teaching assistants, and other students; and essays, answers to questions, and other items submitted to satisfy course requirements.|
|Student Payment Data||If you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code. For security, KOOATI does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.|
|Data About Your Accounts on Other Services||We may obtain certain information through your social media or other online accounts if they are connected to your KOOATI account. If you login to KOOATI via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday, and list of friends or contacts.Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.|
1.2 Automated Usage Data
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Website.We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when (like time and date) you use our Website and other technical information and diagnostic data. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.When you access the Services (including browsing courses), we collect certain data by automated means, including:
|System Data||Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).|
|Usage Data||Usage statistics about your interactions with the Services, including courses accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Services (“Usage Data”).|
|Approximate Geographic Data||An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.|
The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.
1.3 Information Collected Through our Website
In Short: We may collect information regarding your mobile device, push notifications, when you use our apps.If you use our App, we may also collect the following information:
Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
2. How do we collect date?
1.1 What Is Cookies?
|Authentication and security||
For example, cookies help authenticate your access to KOOATI and prevent unauthorized parties from accessing your accounts.
For example, cookies help us remember your preferred language or the country you’re in, so we can provide content in your preferred language without asking each time you visit.
|Analytics and research||
For example, cookies help us show a personalized list of recommended courses on the homepage.
To learn more about targeting and advertising cookies and how you can opt out, visit www.allaboutcookies.org/manage-cookies/index.html, or if you’re located in the European Union, visit the Your Online Choices site.Please note that where advertising technology is integrated into the Services, you may still receive advertising on other websites and applications, but it will not be tailored to your interests.When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide its own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.
What are my privacy options?
Updates & Contact Info
Your data protection rights under the general data protection regulations (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. KOOATI aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. If you wish to be informed about what Personal Data, we hold about you and if you want it to be removed from our systems, please contact us:In certain circumstances, you have the following data protection rights:
Please note that we may ask you to verify your identity before responding to such requests.You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA) or home country.
3. How do we use your information?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity.We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.We use the information we collect or receive:
Use Of Data Legal Basis For Processing Personal Data Under The General Data Protection Regulation (GDPR)
To comply with the law
4. Will your information be shared with anyone?
5. How long will you keep information?
6. How do you keep my information safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
Storing And Transferring Your Personal Data
Security of Data
The security of your 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. We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account. KOOATI takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and KOOATI, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact our Support Team with any concerns.
7. What are my privacy rights?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.
Account InformationIf you would at any time like to review or change the information in your account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and/or comply with legal requirements.Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
7.1 Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.
7.2 Accessing, Updating, and Deleting Your Personal DataYou can access and update your personal data that KOOATI collects and maintains as follows:
7.3 Our Policy Concerning Children
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children under 13 (or under 16 in the European Economic Area) should not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.Parents who believe that KOOATI may have collected personal data from a child under those ages can submit a request that it be removed to firstname.lastname@example.org.
7.4 Jurisdiction-Specific RulesDepending which country you are from, you have certain rights related to accessing and deleting your data, as well as learning who we share your data with. If you live in Australia, you have the right to make a formal complaint with the appropriate government agency. Users outside of the United States should note that we transfer data to the US and other areas outside of the European Economic Area.
Users in California
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included in these rights are:
Additionally, for more information about the personal information we collect and how we collect it, please see the sections above entitled “What Data We Get” and “How We Get Data About You.”To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers who have access to your personal information, please see the sections above entitled “What We Use Your Data For” and “Who We Share Your Data With.”Most importantly, per the CCPA,
KOOATI does not sell your personal information or the personal information of any of our users.As a California resident, you also have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to email@example.com with the phrase “California Shine the Light” and include your mailing address, state of residence, and email address.Since the internet industry is still working on Do Not Track standards, solutions, and implementations, we do not currently recognize or respond to browser-initiated Do Not Track signals.
Users in Nevada
As is the case for all of its users, KOOATI does not sell its users’ personal information or personal data. Nonetheless, if you are a resident of Nevada, and would like to request that we do not sell your personal information, you can request to opt out of the sale of covered information by emailing firstname.lastname@example.org.
Users in Australia
If you are an Australia resident and you have a complaint, you may refer it to the office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by visiting www.oaic.gov.au; forwarding an email to email@example.com; telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001.
Users Outside of the U.S.
In order to provide the Services to you, we must transfer your data to the United States and process it there. By visiting or using our Services, you consent to storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in the United Kingdom (“UK”), Switzerland, and the European Economic Area (“EEA”) is transferred and stored outside those areas. Additionally, if you are located in the UK, EEA, or Switzerland, you also have the right to lodge a complaint with your data supervisory authority.That data is also processed outside of the UK, Switzerland, and the EEA by our KOOATI group companies, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by KOOATI and its processors.
8. Control for Do-Not-Track-Features
In Short: We use Analytics, Google Analytics, Behavioral remarketing, Facebook and links to third party sites.We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
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 contextualise and personalise the ads of its own advertising network.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Facebook remarketing service is provided by Facebook Inc.You can learn more about interest-based advertising from Facebook by visiting this page.To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook.Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA and the Digital Advertising Alliance of Canada in Canada or the European Interactive Digital Advertising Alliance in Europeor opt-out using your mobile device settings.For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy.
Zoom Video Conference
Zoom is used to organize online coaching sessions and meetings with students online as a third-party. While most businesses have been severely impaired by the current restrictions on travel and office access in order to stem the spread of COVID-19, there are also a few beneficiaries of the worldwide lockdown. One of them is video communications service provider Zoom, with its daily meeting participants count rising from about 10 million in December 2019 to almost 300 million in April 2020. Zoom Data Privacy and Cybersecurity Implications
For information on the privacy practices of Stripe, please visit Stripe’s Data Policy.
We use Woocommerce for selling tickets.
Links To Third Party Sites
We offer third party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites. Please check the individual policies before you submit any information to those services.
11. Do you make updates to this policy?
12 How can I contact you about this policy? If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), KOOATI by email at firstname.lastname@example.org
© 2020 KOOATI. All rights reserved.
© 2020 KOOATI. All rights reserved.