Privacy Policy

This Privacy Policy was last updated on October 1, 2020.

Who We Are

Welcome to KOOATI and thank you for choosing to be part our online music education marketplace and music community connecting musicians with students worldwide. We take privacy very seriously at https://kooati.com. Websites and mobile Application (the “Website” and the “App”), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites” and “Services”), operated by KOOATI ( “we”or “us” or “our”) and we are fully committed to protecting your privacy. It is our policy to respect your privacy regarding any information we may collect from you across our Websites https://kooati.com, and Apps, and other sites and services we own and operate. This Privacy Policy (this “Privacy Policy”) exists to be as clear and straightforward as possible, because we know that you (“you,” “user,” “site user,” or “valued user”) care about how information you provide to us is used and shared. Our aim is for you — a valued user of our site — to always feel informed and empowered with respect to your privacy on KOOATI..com We hope you take some time to read through it carefully, as it is important and it will help you make informed decisions about sharing your personal information with us.

By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Website and our Services. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@kooati.com.

 
Data Controller 
  1. We only ask for personal information when we truly need it to provide a Service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used.
  2. We only retain collected information for as long as necessary to provide you with your requested Service. What data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.
  3. We don’t share any personally identifying information publicly or with third-parties, except when required to by law.
  4. Our Website may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies.
  5. You are free to refuse our request for your personal information, with the understanding that we may be unable to provide you with some of your desired Services.
  6. Your continued use of our Website will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about how we handle user data and personal information, feel free to contact us.

Definitions 

Service: Service means the Websites https://kooati.com, and Apps, and other sites and services we own and operate.
Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

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).

Cookies: Cookies are small files stored on your device (computer or mobile device).
 
Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.


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.

 
Table of Content 
  1. What Information Do We Collect?
  2. What Are Cookies?
  3. How Do We Use Your Information?
  4. Will Your Information Be Shared with Anyone?
  5. How Long Do We Keep Your Information?
  6. How Do We Keep Your Information Safe?
  7. What Are Your Privacy Rights?
  8. Controls for Do-Not-Track Features
  9. Which Service Providers Do You Use?
  10. Do We Make Updates to This Policy?
  11. How Can You Contact Us About This Policy?

 

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.

Account Data

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.
Music Coach Payment Data If you are an instructor, you can link your PayPal, Payoneer, or other payment account to the Services to receive payments. When you link a payment account, we collect and use certain information, including your payment account email address, account ID, physical address, or other data necessary for us to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include residency information, tax identification numbers, biographical information, and other personal information necessary for taxation purposes. For security, KOOATI does not collect or store sensitive bank account information. The collection, use, and disclosure of your payment, billing, and taxation data is subject to the privacy policy and other terms of your payment account provider.
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.
Sweepstakes, Promotions, and Surveys We may invite you to complete a survey or participate in a promotion (like a contest, sweepstakes, or challenge), either through the Services or a third-party platform. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, date of birth, or phone number. That data is subject to this Privacy Policy unless otherwise stated in the official rules of the promotion or in another privacy policy. The data collected will be used to administer the promotion or survey, including for notifying winners and distributing rewards. To receive a reward, you may be required to allow us to post some of your information publicly (like on a winner’s page). Where we use a third-party platform to administer a survey or promotion, the third party’s privacy policy will apply.
Communications and Support If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.

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:

  • Mobile Device Access.We may request access or permission to certain features from your mobile device, including your mobile device’s contacts, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Data.We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

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?
A cookie is a small file containing a unique identifier that is placed in the web browser of your computer or mobile device when you visit a site. Cookies and similar technologies (which include pixels, tags, web beacons and software development kits (“SDKs”)) (together “cookies”) enable site operators to recognize your device and collect information from it when you interact with a site. They use this information to understand how the site is being used, remember user preferences and improve users’ browsing experience. Cookies are also used to make the advertising you see online more relevant to your interests.We use cookies and similar technologies like web beacons, pixel tags, or local shared objects (“flash cookies”), to deliver, measure, and improve our services in various ways. We use these cookies both when you visit our site and services through a browser and through our mobile app. As we adopt additional technologies, we may also gather additional data through other methods.We use cookies for the following purposes:

Authentication and security
  • To log you into KOOATI
  • To protect your security
  • To help detect and fight spam, abuse, and other activities that violate KOOATI’s agreements

For example, cookies help authenticate your access to KOOATI and prevent unauthorized parties from accessing your accounts.

Preferences
  • To remember data about your browser and your preferences
  • To remember your settings and other choices you’ve made

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
  • To help us improve and understand how people use KOOATI

For example, cookies help us test different versions of KOOATI to see which features or content users prefer, web beacons help us determine which email messages are opened, and cookies help us see how you interact with KOOATI, like the links you click on.We also work with a number of analytics partners, including Google Analytics and Mixpanel, who use cookies and similar technologies to help us analyze how users use the Services, including by noting the sites from which you arrive. Those service providers may either collect that data themselves or we may disclose it to them.You can opt out of some of these services through tools like the Google Analytics Opt-out Browser Add-on and Hotjar Opt-Out Cookie.

Personalized content
  • To customize KOOATI with more relevant content

For example, cookies help us show a personalized list of recommended courses on the homepage.

Advertising
  • To provide you with more relevant advertising

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?

You have a number of options to control or limit how we and our partners use cookies:

  • Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by consulting your browser’s support articles. If you decide to decline cookies, please note that you may not be able to sign in, customize, or use some interactive features in the Services.
  • Flash cookies operate differently than browser cookies, so your browser’s cookie-management tools may not remove them. To learn more about how to manage Flash cookies, see Adobe’s article on managing flash cookies and Website Storage Settings panel.
  • To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Union, visit the Your Online Choices site. To opt out of Google Analytics’ display advertising or customize Google Display Network ads, visit the Google Ads Settings page.
  • For general information about targeting cookies and how to disable them, visit www.allaboutcookies.org.

Updates & Contact Info
From time to time, we may update this Cookie Policy. If we do, we’ll notify you by posting the policy on our site with a new effective date. If we make any material changes, we’ll take reasonable steps to notify you in advance of the planned change.If you have any questions about our use of cookies, please email us at support@kooati.com.

1.2 Tracking & Cookies DataWe use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection. When you visit or interact with our App, we or our authorized service providers may use cookies, and other similar tracking technologies to track the activity on our Service and hold certain information to help provide you with a better, faster, and safer experience and for advertising purposes.As detailed in our Cookie Policy, KOOATI and service providers acting on our behalf (like Google Analytics and third party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools”) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.We use cookies (small files that websites send to your device to uniquely identify your browser or device or to store data in your browser) for things like analyzing your use of the Services, personalizing your experience, making it easier to log into the Services, and recognizing you when you return. We use web beacons (small objects that allow us to measure the actions of visitors and users using the Services) for things like identifying whether a page was visited, identifying whether an email was opened, and advertising more efficiently by excluding current users from certain promotional messages or identifying the source of a new mobile app download.KOOATI uses the following types of cookies:

  • Preferences: cookies that remember data about your browser and preferred settings that affect the appearance and behavior of the Services (like your preferred language).
  • Security: cookies used to enable you to log in and access the Services; protect against fraudulent logins; and help detect and prevent abuse or unauthorized use of your account.
  • Functional: cookies that store functional settings (like the volume level you set for video playback).
  • Session State: cookies that track your interactions with the Services to help us improve the Services and your browsing experience, remember your login details, and enable processing of your course purchases. These are strictly necessary for the Services to work properly, so if you disable them then certain functionalities will break or be unavailable.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional.Some of the third-party partners who provide certain features on our site may also use Local Storage Objects (also known as flash cookies or LSOs) to collect and store data.Cookies are pieces of code that allow for personalization of the Service experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes. Cookies help us distinguish you from other users of our Website.We use cookies and similar technologies that only remain on your device for as long as you keep your browser active (session) and cookies and similar technologies that remain on your device for a longer period (persistent). You are free to block, delete, or disable these cookies if your device permits so. You can manage your cookies and your cookie preferences in your browser or device settings.These are the category of Cookies we use:

  1. Strictly necessary cookies are necessary in order to enable you to move around the Service and use its features. Without these cookies, we would not be able to provide our Services. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
  2. Analytical/performance cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  3. Functionality cookies are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  4. Targeting cookies are recorded when you visit our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.Except for essential cookies, all cookies will expire after a period of six months.

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:

  1. 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.
  2. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  3. The right to object. You have the right to object to our processing of your Personal Data.
  4. The right of restriction. You have the right to request that we restrict the processing of your personal information.
  5. The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  6. The right to withdraw consent. You also have the right to withdraw your consent at any time where All Pro Bono relied on your consent to process your personal information.

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:

  • To facilitate account creation and login process. If you choose to link your account with us to a third-party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
  • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • 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
  • Provide and administer the Services, including to display customized content and facilitate communication with other users;
  • Process your requests and orders for courses, products, specific services, information, or features;
  • Communicate with you about your account by:
    • Responding to your questions and concerns;
    • Sending you administrative messages and information, including messages from instructors and teaching assistants, notifications about changes to our Service, and updates to our agreements;
    • Sending you information, such as by email or text messages, about your progress in courses, rewards programs, new services, new features, promotions, newsletters, and other available courses (which you can opt out of at any time);
    • Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of the mobile app);
  • Manage your account preferences;
  • Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
  • Solicit feedback from users;
  • Market and administer surveys and promotions administered or sponsored by KOOATI;
  • Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;
  • Identify unique users across devices;
  • Tailor advertisements across devices;
  • Improve our Services and develop new products, services, and features;
  • Analyze trends and traffic, track purchases, and track usage data;
  • Advertise the Services on third-party websites and applications;
  • As required or permitted by law; or
  • As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.

Use Of Data Legal Basis For Processing Personal Data Under The General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), KOOATI legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. KOOATI may process your Personal Data because:

    • We need to perform a contract with you
    • You have given us permission to do so
    • The processing is in our legitimate interests and it is not overridden by your rights
    • For payment processing purposes

To comply with the law

4. Will your information be shared with anyone?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. We share certain data about you with instructors, other students, companies performing services for us, KOOATI affiliates, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

  • With Your Music Coachs: We share data that we have about you (except your email address) with instructors or teaching assistants for courses you enroll in or request information about, so they can improve their courses for you and other students. This data may include things like your city, country, browser language, operating system, device settings, the site that brought you to KOOATI, and your activities on KOOATI. If we collect additional data about you (like age or gender), we may share that too. We will not share your email address with instructors or teaching assistants. We also enable our instructors to implement Google Analytics on their course pages to track sources of traffic to their courses and optimize their course pages.
  • With Other Students and Music Coachs: Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and instructors. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable by other users depending on your settings.
  • With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
  • With KOOATI Affiliates: We may share your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services.
  • With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to KOOATI. For example, we work with Benesse in Japan. Depending on your location, we may share your data with these partners.
  • With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like Clearbit, we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 1), or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
  • To Power Social Media Features: The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.
  • To Administer Promotions and Surveys: we may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
  • For Advertising: If we decide to offer advertising in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), and to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads.
  • For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
    • Permitted or required by law;
    • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
    • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
    • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
    • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
    • Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of KOOATI, our users, employees, members of the public, or our Services.
    • We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.
  • During a Change in Control: If KOOATI undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
  • After Aggregation/De-identification: we can disclose or use aggregate or de-identified data for any purpose.
  • With Your Permission: with your consent, we may share data to third parties outside the scope of this Privacy Policy.

5. How long will you keep information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

Retention Data

KOOATI will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us keeping your personal information for longer than 1 year past the termination of the user’s account.When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.Kooati 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 periods.

 

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. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored on secure servers. All electronic transactions entered into via our Service will be protected by SSL encryption technology.International Transfers of your Personal Data. Your personal data may be transferred to, and processed and stored in, countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Economic Area (“EEA”), your personal data may be processed outside of the EEA, including, for example, in the United States (an “International Transfer”). Any International Transfers of your personal data are made either: (a) to a country or territory ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission; (b) to a third party that is a member of a compliance scheme recognised as offering adequate protection for the rights and freedoms of data subjects as determined by the European Commission, such as the EU-U.S. Privacy Shield; or (c) pursuant to appropriate safeguards, such as the Standard Contractual Clauses (processors) approved by European Commission Decision C(2010)593 or any subsequent version thereof released by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Policy.


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:

  • Log into your account settings and update your user account.
  • Contact us using the contact information provided.

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:

  • Access your account settings and update preferences.
  • Contact us using the contact information provided.

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:

  • To update data you provide directly, log into your account and update your account at any time.
  • To terminate your account:
    • If you are a student, visit your profile settings page and follow the steps detailed here.
    • If you are an instructor, follow the steps detailed here.
    • If you have any issues terminating your account, please contact our Support Team.
    • Please note: even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users (including in course comment); (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.
  • To request to access, correct, or delete your personal data, please use our online form here. You can also submit these requests by emailing support@kooati.com. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

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 support@kooati.com.

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:

  • “Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
  • “Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
  • “Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, KOOATI will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.

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 support@kooati.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 support@kooati.com.

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 enquiries@oaic.gov.au; 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
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

9. Which service providers do you use? 

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.

Analytics
We may use third-party Service Providers to monitor and analyse 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 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

Behavioral Remarketing
KOOATI uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Facebook
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

Each user on KOOATI will have to connect and pay for their own Zoom account. KOOATI does not cover any costs or take any responsibility. KOOATI is a platform for users over 18 years old. For users under 18, we strictly and highly recommend to have parents consent and one parent or an adult present during the Zoom meetings at all time. Read more:
 

Payment processing 
We use third-party services for payment processing. We use PayPal, Stripe and Klarna.se to process our transactions. Their Privacy Policy can be views on their website. It´s reliable, secure and you don’t need an account in order to use the service. We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing. 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. We use appropriate security measures to protect your information by taking reasonable precautions and follow industry best practices. We secure server and sensitive information that is transmitted via SSL technology, follow all PCI-DSS requirements and implement additional generally accepted industry standards. Payments taken outside KOOATI’s website is on risk and not KOOATI’s responsibility in anyway. 

Stripe
For information on the privacy practices of Stripe, please visit Stripe’s Data Policy.

Paypal
If you choose to use PayPal to make purchases through the Sites, you will be directed to the PayPal website and provide your payment information directly to PayPal. PayPal’s privacy policy applies to the information you provide on the PayPal website. If you prefer to pay with a credit card via PayPal, you do not need to have a PayPal account to proceed with your payment. You can proceed as a guest and pay with your credit or debit card by selecting “Pay without a Paypal account” option at checkout. Your address, e-mail, phone number, etc, may also be requested depending on your country. When you are done, select “Pay Now” and that’s it. If there is a pop-up window requesting to “Create a Paypal account (Optional)”, just select a “No thanks” option.For information on the privacy practices of Paypal, please visit Stripe’s Data Policy

Klarna
Klarna is a payment gateway in these countries Australia Austria Belgium Denmark Finland Germany Italy Netherlands Norway Spain Sweden Switzerland United Kingdom United States.In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice. and Klarna’s Privacy Policy. Woocommerce
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?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

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 support@kooati.com

© 2020 KOOATI. All rights reserved.

KOOATI is an online music education marketplace connecting professional musicians with aspiring musicians worldwide.

© 2020 KOOATI. All rights reserved.

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