Privacy Policy

PRIVACY POLICY

The following privacy policy (“Privacy Policy”) sets forth OneDueTres Languages LLC’s (“Company”) policy with respect to information, including personally identifiable data (“Personal Data”) and other information, Company collects from visitors to the Company website located at www.oneduetreslnaguages.com (“Website”). Company, owner and operator of the Website, is a limited liability company formed under the laws of the state of Virginia, United States.

We respect your privacy and are committed to protecting it. The purpose of this Privacy Policy is to inform you what Personal Data we may collect and how it may be used. This statement only applies to this Website and the courses advertised therein (“Courses”). This Privacy Policy does not apply to information of any kind that we collect by means (including offline means) or from sources other than those specified herein.

1. Your Privacy

Company recognizes that your privacy is very important to you and believes that your Personal Data should be treated with respect.

Before providing us with any information, you should read through this policy so that you understand and are comfortable with exactly how we will collect and what we will do with any information you share with us. This Privacy Policy will also tell you how to access your information and/or seek correction of your information if desired.

By using the Website or Courses and providing Personal Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to the Website, Courses, and your account information and usage.

Please refer to Section 15 at the end of this Privacy Policy for our contact details should you wish to contact us about this Privacy Policy or our privacy practices.

2. What We Collect

Personal and Non-Personally Identifiable Information

We collect Personal Data as well as non-personally identifiable information on the Website and in the Courses.

“Personal Data,” as used in this Policy, is personally identifiable information, such as your first and last name, mailing address, email address, billing information, IP addresses, demographics, passwords, telephone numbers and/or other online contact information. “Personal Data” can also include data that is usually non-personally identifiable information (such as location data, data about personal attributes or online identifiers) but that, taken together with other collected data, identifies a natural person, either directly or indirectly.

Sensitive Information

We do not collect Sensitive Information from users for marketing purposes.

“Sensitive Information” includes information about a person’s racial or ethnic origin, religious beliefs or affiliations, political opinions, philosophical beliefs, health or genetic information, sexual preference or information about whether an individual is a member of a professional or trade association or union.

Sensitive information might be collected during the course of surveys or competitions administered by Company or its affiliated third parties, but only if volunteered by you with your consent.

You can choose not to actively volunteer information to Company. However, if you do provide information to Company, including Sensitive Information, you are also providing consent for Company to collect, store and use that information as set forth in this Privacy Policy.

3. How We Collect Information

We collect information in three ways.

(1) Voluntarily

(2) Automatically

(3) Via Third Party Sources

Voluntarily

We collect information you provide to us in voluntary submissions, including but not limited to:

(1) registration forms or user profiles, when you provide your name, email address or other information to us voluntarily;

(2) subscriptions, when you sign up to our Courses or newsletters by providing your name and email address;

(3) entries to promotions, sweepstakes, competitions or contest, by providing your name and email address and other Personal Data depending on the entry requirements;

(4) feedback communications or customer service requests, where you may supply or we may ask for your name and contact details;

(5) software and mobile application downloads, where you may provide your name and contact details and other information for the purposes of signing up to the application and obtaining its services;

(6) curriculum vitae submissions, where you provide your Personal Data to us; and

(7) business submissions, ideas, plans and other information relating to your business strategy and/or activities.

Our legal basis for processing this information is your consent, and by voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred and stored from your current location to the offices and servers of Company and the authorized third parties referenced below.

Automatically

We create and record information automatically when you visit the Website and Courses. We use cookies (or files sent directly to your computer or device) and other similar technology to collect information such as your IP address, the site you visited immediately prior to our Website and the frequency and duration of your visit to our Website.

We may track activity relating to your interaction with our email communications and with links contained within our email communications and our Website or Courses.

We may also collect, use, and share, with Company’s partners, service providers and licensees, precise location data, including the real-time location of your mobile or fixed location device.

The Website or Courses may log information using cookies, which are small data files stored on your browser. The Website and Courses may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to enhance your experience when visiting our Website or Courses. Wherever possible, we anonymize and pseudonymize your Personal Data.

See below for more information about how Personal Data and non-personally identifiable information is used in relation to marketing and advertising

Via Third Party Sources

We may also obtain Personal Data, from third party sources. For example, if you use a third-party software through the site, they may transfer information to us for fulfillment. We do not control the data privacy or protection policies of third parties, and we are not responsible for the privacy practices of these third parties. Our legal basis for processing this information is our legitimate interests, namely monitoring and improving our services, and the legitimate interests of our customers.

This may include soliciting third parties to collect non-personally identifiable and personally identifiable information on our behalf. In such cases we instruct those third parties to comply with this policy and require confirmation of their compliance with applicable privacy laws and regulations.

We may use analytics tools and other third-party technologies, to collect non-personally identifiable information in the form of various usage and user metrics when you use the Website or Courses. These third-party analytics companies may combine the information collected for us with other information they have independently collected across their network of websites, products and services.

Many of these companies collect and use information under their own privacy policies.

For example, we have implemented Google Analytics Advertising features to collect data about your traffic via Google advertising cookies and identifiers.

The Course is hosted on Thinkific. Please refer to Thinkific’s terms of use and privacy policy for further information about Thinkific’s treatement of your data.

At the moment we only use these tools to collect non-personally identifiable information. We will only use these tools to collect personally identifiable information with your express, informed consent. We do not identify users or merge non-personally identifiable information that we collect with other information to make it personally identifiable.

You may, at any time, opt out of the data collection or analytics practices offered by the third-party organizations that we use on our Website or Courses.

4. Security and Integrity

We take measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all Personal Data that we collect. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps.

5. Storage

We store your information on networks in the United States and take steps to protect your Personal Data from misuse, loss or unauthorized access. These reasonable steps include password access, firewalls, and secure servers.

6. How We Use Information

Generally, we use Personal Data to establish and enhance our relationship with our users through four main categories:

(1) Communication

(2) Optimization

(3) Marketing & Advertising; and

(4) Sharing Features.

Below, we provide some specific examples of how we use the information we collect.

Communication and Responding to Requests

To provide you with customer support, share communications such as newsletters, process transactions, respond to users’ requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and connect users to the Website, Courses, and/or services and to products and services of our partners and licensees.

Optimization

To provide, improve, and maintain our Website, Courses and services, to develop new products and services, to prevent abuse, fraud or other unauthorized or illegal activity, to personalize, display, track and measure advertisements and other content for you, and for other administrative and internal business purposes.

Marketing & Advertising

To personalize and display advertisements and other content for you, we may drop a cookie on your browser linked to data that is known about you so that third party advertisers can show you more relevant ads.

We may also use various measurement services and companies to analyze collected data about your engagement with our Website, Course, and services. Unless you have provided us with express, informed consent to collect your Personal Data for targeted marketing and advertising purposes, the information that is collected is not personally identifiable, and is pseudonymous or aggregated data that does not identify any individual user.

The third-party analytics companies that we use may share the user information they collect from our Website and Courses with other measurement companies, who gather data from various sources, analyze and report on it for their clients. The reported information will cover various elements, for example it may summarize how many people have viewed a certain webpage within a certain age bracket.

In some instances, the non-personally identifiable information collected from our Website, Courses and/or services may be linked with information collected by a third-party source, such as Google Analytics, to become personally identifiable. We will not link, or merge non-personally identifiable information collected by us with personally-identifiable information collected by a third party organization, such as Google Analytics, without your informed, express consent. Google may merge or link your information with the non-personally identifiable information collected from our Website, Course, and/or services if you have expressly provided your consent for them to do that.

By using our Website, Courses and services, you consent to the collection of data by Company’s ad servers or third party affiliates, or the transfer of information to them, wherever necessary, for the Website and Courses performance optimization and in order to tailor the content and advertising that appears on our Website and Courses.

You are entitled to opt out of personalized marketing and advertising at any time. See below for opt out options.

Sharing Features

To provide you with various ways to connect and share content with third parties.

By using any third-party service to share links to our content, you permit us to access, use and disclose information relating to your account on each such third party service (such as your user name and profile information) if available to us through the third party service.

European Union and European Economic Area

This section is relevant to users that are based in or that access the Website, Courses and services from the European Union and the European Economic Area (“EU Users”).

In accordance with the General Data Protection Regulations, which came into force on 25 May 2018, we do not direct personalized advertising and marketing to users in the European Union. This includes tracking EU Users’ activity or targeting EU Users with advertising that uses Personal Data.

As explained in the section above, we may use cookies and other tags to display advertisements to EU Users based on non-personally indefinable information, anonymous data, or aggregated data that we have collected in connection with an EU Users’ interaction with our Website, Courses and services.

We will not track your activity or target you using your Personal Data without your express, informed consent. When requesting your consent, we will provide clear information about the ways that we use your Personal Data. Consent may include requesting that you opt in to particular activities or that you expressly provide your preferences in relation to particular activities.

Below are the types of lawful basis that we will rely on to process your Personal Data:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at support@oneduetreslanguages.com or onedueterslanguages@gmail.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.

Consent means where you have consented to a certain use of your Personal Data.

7. When We Disclose Personal Data

Company will not sell, license or otherwise disclose your Personal Data to third parties unless such disclosure is for the purposes set out in this Privacy Policy. Company may share your Personal Data with certain third parties as set forth below:

Between Company’s Networks.

In order to ensure that the Website, Courses and services work together optimally, as described above, we share information (including your information) between our multiple online networks.

Service Providers

We may provide Personal Data to our third-party service providers for their use in performing internal business functions or collecting information on our behalf, including database hosting and data processing services, and assist us in responding to requests by you for information that you request.

Whenever possible, we require such third parties to only collect and use Personal Data in accordance with this Policy, and for no purpose other than providing us with our requested services.

Company’s Partners

When you visit or use a part of any Website, Course, product and/or service that is co-branded or that is a part of a joint promotion involving Company and one or more third parties (each a “Co-Branded Party”), you are providing and consenting to provide your collected information to Company and each of the Co-Branded Parties. Please note that we do not control any Co-Branded Parties’ use or treatment of information. You should consult each of their joint or separate privacy policies to determine your rights with respect to their use and treatment of your information.

We may share your email address with one or more of our third-party business partners in order to facilitate advertisement tailoring for our users.

Legal Requirements

Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Website or Courses or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our Customer contracts.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Parent Companies and Affiliates

We may share your information with a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), provided that we require our Affiliates to honor this Privacy Policy.

Related Companies

We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Third Parties with Permission

We may share your information with third parties to whom you ask us to send your information.

Agents, Consultants, and Related Third Parties

Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Interactive Features

Any Personal Data that you submit, display, or publish on a forum, blog, channel, bulletin board, chat room, user commenting feature or other interactive sharing or social feature offered through our Website, Courses, and/or services, is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us and other third parties without restriction, except to the extent limited access features are available.

Except when required by law, Company will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, Company may disclose or transfer personal information collected through the Website or Courses to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

8. Anonymous Data

From time to time, Company may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.

9. Advertising

Retargeting Ads

From time to time, the Website or Courses may engage in remarketing efforts with third-party companies, such as Google, Facebook, or Instagram, in order to market the Website or Courses. These companies use cookies to serve ads based on someone's past visits to the Website or Courses. This means, after visiting the Website, you may see an ad for our services. However, your personally identifiable information is not used by any remarketing service other than to present you offers from Company. We use the following third-party service providers for remarketing:

Facebook: Opt-out of Facebook remarketing here

Google: Opt-out of Google remarketing here

Newsletters

On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, Company may see if and when you open an email and which links within the email you click. Also, this allows Company to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.

10. Your Choices

Under laws in certain countries in which we operate, customers and other visitors to our Website or Courses from those countries have a right to access Personal Data about themselves, and to amend, correct or delete Personal Data that is inaccurate, incomplete or outdated. We will, upon request, provide you with confirmation regarding whether we are processing Personal Data about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your Personal Data that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Data that you request.

Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.

Submitting Personal Data

Please note that if you do not wish to submit Personal Data, you may not be able to access and/or participate in/on the Website, Courses and/or services that require your Personal Data. For example, you will not be able to register for an account with us, participate in certain contests or promotions, purchase products or access and/or use certain product features or online services. In addition, your refusal to submit Personal Data may limit our ability to respond to your customer support inquiry in a timely fashion.

Unsubscribing

If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You can opt out of receiving communications from us at any time by clicking the “unsubscribe” link in communications you receive from us.

By opting out of one particular electronic communication received from us, you will be removed from the subscriber list in connection with that particular communication category or “newsletter”. However, you will continue to receive communications in relation to other newsletters to which you subscribed, and have not opted out.

Please note that if you unsubscribe from our communications, we may still send you relevant administrative or security notices from time to time.

Accessing Personal Data

You may request access to any Personal Data we hold about you by contacting us as per the details under the enforcement section in this Policy. Whenever you are entitled to access such information, we will provide such information to you via email or post.

Editing Personal Data

You may, at any time, update, correct, or delete certain Personal Data that you have provided to us by contacting us as per the details under the enforcement section in this Policy. You are entitled to request that your Personal Data is dealt with by us either anonymously or under a pseudonym.

Forgetting Personal Data

In certain situations, you may request that we erase or forget your Personal Data. To do so, please contact us as set forth in section 15, enforcement. Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law.

Cookies and Similar Technology

The Website and Courses uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customize content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein.

Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if users deactivate the setting of cookies in your Internet browser, not all functions of our Website or Courses may be entirely usable.

Children’s Information

The Website and Courses do not knowingly collect any personally identifiable information from children under the age of 16. If a parent or guardian believes that the Website or Courses have personally identifiable information of a child under the age of 16 in its database, please contact us immediately as set forth in section 15, enforcement and we will use our best efforts to promptly remove such information from our records

11.

Third Party Services and Links

Occasionally we will include links to third party websites on our Website or Courses or communications with you. Whenever you choose to follow such links to any other websites you should be aware that our privacy policy no longer applies and that each third party website’s privacy policy will govern their collection, storage and use of any of your Personal Data from the moment you follow the link. Theses links do not imply that Company endorses or has reviewed the third-party sites. We suggest contacting those sites directly for information on their privacy policies.

12. Arbitration

This Privacy Policy will be governed and construed in accordance with the laws of the State of Virginia. Any controversy or claim arising out of or relating to the Privacy Policy, or the breach thereof, shall be settled by arbitration administered by the American Arbitration Association ("AAA") under its Commercial Arbitration Rules, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The place of any such arbitration shall be in or near Virginia Beach, Virginia. The parties also agree that the AAA Optional Rules for Emergency Measures of Protection shall apply to the proceedings.

13. Other Terms and Conditions

Your access to and use of the Website or Courses may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Company. Please refer to those agreements as needed.

Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.

14. Changes and Updates to This Policy

This Privacy Policy was last updated on _/_/2019 and may be updated by us, from time to time, in our sole discretion without prior notice. The current version of the Privacy Policy will be available on our Website.

We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Data. Your continued use of our Website, or Courses and/or services after any update or modification constitutes your agreement to this Privacy Policy. =

15. Enforcement

Please feel free to direct any questions concerns or complaints regarding our Privacy Policy or Company’s treatment of Personal Data by contacting us at support@oneduetreslanguages.com or onedueterslanguages@gmail.com or by writing to us at OneDueTres Languages LLC, 4445 Corporation Ln, STE 445 Virginia Beach, VA 23462.

Users in the European Union and European Economic Area have the right to lodge a complaint with the relevant supervisory authority in their member state. We encourage you to contact us first so that we can respond to your concerns. We will do our best to resolve them promptly in accordance with relevant laws and policies.

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