(the “Site”) and the services, features, content or applications we offer (together with the Site, the “Services”).We receive information about you from various sources, including: (i) if you register for the Site and the Services, through your user account on the Services (your “Account”); (ii) your use of the Services generally; and (iii) from various third party websites and other services. All defined terms not defined herein shall have the meaning ascribed to them in the Terms of Service.What does our policy cover?
.Note that we may also process Personal Data of our users’ own customers, end users, or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data for purposes of the GDPR. If we are the processor of your Personal Data (i.e., not the controller) for purposes of the GDPR, please contact the controller of your Personal Data (i.e., the user or individual providing the course, product, or other offering in connection with which you provided your Personal Data) in the first instance to address your rights with respect to such data.What Personal Data does Criya Collect From You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
First and last name
Billing zip code and/or country of residence
In order to collect payments on your behalf from your customers, and provide payments to you, we, using Stripe as a third-party payment processor, collect payment information from you, your attendees and customers, your vendors, and other parties to whom we provide payments on your behalf and from whom we collect payments on your behalf. This information is used solely to collect and provide payments related to the Services, and is only stored by Stripe. You should review the terms of service and privacy policies of Stripe, available at https://stripe.com/us/legal
.Information we receive from third party sources: We have built services from some third parties into the Site, and those third parties provide us with Personal Data about you, such as the following:
Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (for example, signing up for an account with Facebook Connect), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our Site and Services.
Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:
Web browser information
Page view statistics
Usage information and click tracking
Transaction information (e.g. transaction amount, date and time such transaction occurred)Cookies and other tracking technologies (see below for more information)Log data (e.g. access times, hardware and software information)
Additional Information about Cookies:
or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/
.Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Additional information about interest-based advertisements.”You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Services and functionalities may not work.To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find our more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/
.Additional information about interest-based advertisements:
We may serve advertisements, and also allow third party ad networks, including third party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of Third Parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about Interest-Based Ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt out pages, which are located at http://www.networkadvertising.org/choices/
. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/
.We do not share your Personal Data with advertisers without your consent. However, if you click on or otherwise interact with an advertisement there is a possibility that the advertiser may place a Cookie in your browser and note that it meets the criteria they selected.How Do We Use Your Personal Data?
We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
Communicate with you about the Services
Protect against or deter fraudulent, illegal or harmful actions
Allow you to create and/or manage your digital storefront, your sales pages, and your online services
Allow you to create, manage, and/or subscribe to membership software
Allow you to create, manage, and/or sell digital files
Allow you to create, manage, and/or sell digital downloads and online courses
Contact you about Service announcements, updates or offers
Personalize website content and communications based on your preferences
Provide support and assistance for the Services
Discover others who might be interested in the Services
To identify trends and other statistical information that may be useful to our business
Comply with our legal or contractual obligations
We process the following categories of Personal Data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
First and last name
User Content (which can include Personal Data if you include Personal Data in such content)IP address
Billing zip code and/or country of residence
We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
First and last name
Billing zip code and/or country of residence
Examples of these legitimate interests include:
Protection from fraud or security threats
Operation and improvement of our business, products and services
Marketing of our products and services, directly to you and to others
Provision of customer support
Compliance with legal obligations
Completion of corporate transactions
In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds:
From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.How and With Whom Do We Share Your Data?
Fraud prevention service providers
Analytics service providers
Hosting service providers
Marketing service providers
Staff augmentation and contract personnel
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)Social media services (if you interact with them through your use of the Services)Third party business partners who you access through the Services, including vendors
Other parties authorized by you
We also share Personal Data when we believe it is necessary to:
Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
Protect us, our business or our users, for example to enforce our Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Maintain the security of our products and services.
As part of the Services, you will receive from Criya email and other communications. You acknowledge and agree that by availing yourself of the Services, you allow Criya to send you email and other communication that it determines in its sole discretion relate to your use of the Services.
We also share information with third parties when you give us consent to do so. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. You need to prevent unauthorized access to your Account and Personal Data by selecting and protecting your password appropriately and limiting access to your device and browser by signing off after you have finished accessing your Account.
We seek to ensure that user account information is kept private. However, Criya cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.Do We Store the Personal Data of Children?
As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at c.What Do Users in the European Union Need to Know?
Rights Regarding Your Personal Data:
By law, users in the European Union, United Kingdom, Lichtenstein, Norway, or Iceland have certain rights with respect to their Personal Data, including those set forth below. For more information about these rights, or to submit a request, please visit your Account settings or email us c Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing us at firstname.lastname@example.org
If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data by emailing email@example.com
. You may also be able to correct some of this information directly by making updates to your account.
You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent:
If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing:
You can ask us to restrict further processing of your Personal Data.
Right to File Complaint:
You have the right to lodge a complaint about Criya's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Criya's and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you
reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Criya's in the U.S. and will be hosted on U.S. servers, and you authorize Criya to transfer, store and process your information to and in the U.S., and possibly other countries. If you live in the European Union, Iceland, Liechtenstein, or Norway, you hereby consent to the transfer of your data in accordance with Exhibit B to the EU Data Processing Addendum. Please contact us at firstname.lastname@example.org
with any questions or concerns.What If You Have Questions Regarding Your Personal Data?
760 Newhall Drive #1106