Privacy Policy
This Privacy Policy governs the manner in which the School collects, uses, maintains and discloses information collected from users (each, a “Student”) of the School. This Privacy Policy applies to the School and all Courses offered by the School.
Personal identification information
We may collect personal identification information from Students in a variety of ways, including, but not limited to, when Students enroll in the School or a Course within the School, subscribe to a newsletter, and in connection with other activities, services, features, or resources we make available in our School. Students may visit the School anonymously. We will collect personal identification information from Students only if they voluntarily submit such information to us. Students can refuse to supply personal identification information but doing so may prevent them from engaging in certain School related activities.
How we use collected information
The School may collect and use Students’ personal identification information for the following purposes:
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To improve customer service
Information you provide helps us respond to your customer service requests and support needs more efficiently. -
To personalize user experience
We may use information in the aggregate to understand how our Students as a group use the services and resources provided in our School. -
To send periodic emails
We may use Student email addresses to send Students information and updates pertaining to their order. Student email addresses may also be used to respond to Student inquiries, questions, or other requests.
Sharing your personal information
We do not sell, trade, or rent Student personal identification information to others.
Third party websites
Student may find advertising or other content in our School that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from our School. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Student, is subject to that website's own terms and policies.
Changes to this Privacy Policy
The School has the discretion to update this Privacy Policy at any time. We encourage Students to frequently check this page for any changes. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.
Your acceptance of these terms
By enrolling in the School, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not enroll in the School. Your continued enrollment in the School following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.
Please note that:
- For Adult Members and Educator Members, your first name and the first initial of your last name will be displayed next to any reviews that you post on our Services by default. Adult Members have the option to create a username in their Profile to display instead of their real name. Teen Members are identified by their username.Your username identifies you on the Services. For instance, YOUR USERNAME IS INCLUDED IN YOUR PROFILE THAT IS VIEWABLE BY OTHER MEMBERS, AND IS DISPLAYED WITH REVIEWS THAT YOU WRITE. SINCE THE USERNAME IS VIEWABLE BY OTHERS, WE SUGGEST THAT YOU NOT USE YOUR REAL NAME FOR YOUR USERNAME OR PASSWORD, TO PROTECT YOUR PRIVACY.
- For Adult Members, when you publish reviews on the Services, the ages of your children are displayed on the reviews by default.
- For Educator Members, when you publish reviews on the Services, the name and location of your worksite are displayed the reviews by default. You can choose to make your worksite information private in your Profile settings.
- If you decide that you no longer want to be a Member, you can delete your account at any time.
- PLEASE NOTE THAT WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF ANY PERSONAL INFORMATION YOU DISCLOSE IN YOUR PROFILE OR ON PUBLIC-FACING AREAS OF THE SERVICES.
B. Collection of Information by Payment Services
Payment Data and Donation Data is processed directly by our Payment Services via payment service pages that we direct you to, or we incorporate into our Site or Apps. When processing payments and donations on our behalf, Payment Services typically act as our ‘processor’ in respect Users’ Payment Data and Donation Data – essentially, this means that they only process your Payment Data and Donation Data for this limited purpose. However, Payment Services may also have their own legal and regulatory obligations that might require them to use your Payment Data and Donation Data for their own compliance-related purposes (e.g., security and fraud prevention) – THIS POLICY DOES NOT ADDRESS PAYMENT SERVICES’ PROCESSING OF PAYMENT DATA FOR SUCH INDEPENDENTLY-DETERMINED PURPOSES, WHICH WILL BE SUBJECT TO THAT PAYMENT SERVICE'S PRIVACY POLICY RATHER THAN THIS POLICY.
C. Automatic data collection
We may automatically log information about you, your computer or mobile device, and your activity over time on our Services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Some of our automatic data collection is facilitated by cookies and similar technologies.
Certain information, like aggregated information or high-level location information, such as the browser language and country during the user session, is treated as non-Personal Information unless applicable law requires otherwise. We may use or disclose such information for any purpose. For instance, we may compile and share aggregate data about the geographic locations or other demographics of our Members, provided that this information does not personally identify any of these Members.
II. OUR USE OF PERSONAL INFORMATION
A. How We Use Personal Information
We use Personal Information for the following purposes:
- Fulfillment of Requests. We may use Personal Information about you to fulfill the purpose for which such information was provided (e.g., to send newsletters to you or respond to your requests or inquiries and provide related customer service).
- Additional Communications. If you register to become a Member of our community or sign up to receive one of our e-newsletters, we may use the Personal Information submitted in connection with your application to contact you with surveys or important communications regarding More Than A. We may additionally use Personal Information to contact you about More Than A content, features, opportunities, and products that may be of interest to you.
- Membership. If you become a Member, we may use your Personal Information to maintain and update your Profile and postings in our online reviews, surveys and polls. All content that you submit to the Services is governed by our Terms of Use. We may also use Personal Information to send updates and communications to our Members, such as our e-newsletters, surveys and other important More Than A communications such as information regarding the Services or changes to our terms, conditions and policies.
- Internal Operations and Analysis. We may also use Personal Information about you for our internal business purposes, such as enhancing or modifying our products and services.
- Law Enforcement; Emergencies; Compliance. We may also use your Personal Information for the purposes described in the Law Enforcement; Emergencies; Compliance below.
You may opt out of receiving our e-newsletters at any time by clicking the "unsubscribe" or “manage my email preferences” links at the bottom of newsletters.
We will not sell or use your Personal Information for targeted advertising or for profiling in furtherance of decisions that produce legal or similar significant effects.
III. HOW WE DISCLOSE INFORMATION COLLECTED ON THE SERVICES
Except as expressly provided in this Policy, we will not share any Personal Information about you without your prior consent.
Profile Information. Each Member has a Profile on the Services. You can change or remove information from your Profile by logging into the Services and clicking the "My Account" links located in your personal Account section.
Your Posts. If you post on our Services or Sessions, the contents of those postings may be displayed on our Services or Sessions along with your name (first name, and first initial of last name) or username, Member photo, Member type, age (if under 18 years of age) and school information (if you are an educator).
Third-Party Service Providers. We work with third-parties who provide services such as data analysis or payment order fulfillment, infrastructure provision, information technology services, content personalization, email delivery services, and market research or third-parties who provide other services to help improve or operate our Services. We may share Personal Information about you with third-parties solely for the purpose of enabling them to provide these services to us. These service providers are given access to Personal Information needed to perform their functions, but are restricted from using the Personal Information for purposes other than providing services for us. When we engage a third-party who will need to access and process your Personal Information as part of their services, we ascertain that the third-party is capable and obligated to provide at least the same level of data privacy and protection as we hold ourselves to. Our third-parties are required to notify us if they determine they can no longer meet the expected level of data privacy and protection, and we monitor for compliance to our data protection terms based on the nature of the services being provided.
Educator Members may disconnect from a linked Single Sign-On Service at any time by visiting the "My Account" or "My Profile" section of the Site.
We will not share any information about you collected on the Services with a linked Single Sign-On Service without your approval. This means that we will not post anything to your Google account or similar unless you give us specific permission to do so, and we will not contact your friends or followers at any time. We do not store or utilize the names of your friends or followers even if they are passed to us by a single sign-on service in the initial registration process.
Single Sign-On Services provide varying levels of control over the extent to which content or information you submit to the Services is also made public and shared on linked Single Sign-On Services. When you use a Single Sign-On Service to log into the Services:
- You share your information with it and its privacy policy applies to the Single Sign-On Service's collection, use, and disclosure of such information.
- In addition, the Single Sign-On Service may be able to collect information about you, including your activity on the Services, and it may notify your connections on the Single Sign-On Service about your use of the Services.
- Such services may also employ unique identifiers which allow your activity to be monitored across multiple websites for purposes of delivering targeted advertising to you.
Law Enforcement; Emergencies; Compliance. Notwithstanding any other provision of this Policy to the contrary, we reserve the right to use your Personal Information, and to disclose it to others, as we believe to be necessary or appropriate: (a) under a requirement of applicable law, (b) to comply with legal process, (c) to respond to governmental requests, (d) to enforce our Terms of Service, (e) to protect our operations, (f) for assistance in fraud detection and prevention; (g) to protect the rights, privacy, safety or property of More Than A, you or others, (h) to permit us to pursue available remedies or limit the damages that we may sustain, and (i) in connection with a disposition of all or a substantial portion of our business, assets or stock, such as the sale of the Site or Services, a merger, consolidation, reorganization, joint venture, assignment, or bankruptcy or similar proceedings.
Personal Information about you may be transferred, stored, and processed by us or the third-parties we work with in countries whose data protection laws and regulations may be different to those of your country. We allow transfers of Personal Information made between countries or regions in a fashion that complies with applicable law.
V. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We keep your Personal Information only for as long as it is warranted to provide our Services, fulfill our commitments to you, and/or adhere to legal or regulatory requirements. If you are a Member, we keep your Personal Information for the duration of our relationship. Certain Personal Information may be kept and archived for longer though, as required for recordkeeping purposes or backing up Services’ data for example. When Personal Information is expired, or is no longer needed and does not have to be retained, we may return, delete, destroy, or anonymize it, depending on what method is systematically and procedurally possible, most secure, and what our related retention commitments are.
VI. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
Links. For your convenience and information, we may provide links to websites and other third-party services and content that is not owned or operated by us. The third-party websites, services and content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that we do not own or control. The inclusion of a link or such third-party services/content on the Services does not imply our endorsement of the linked site, or that content or service.
Security. We seek to use reasonable administrative, organizational, technical, and physical measures to help protect the Personal Information you provide to us from loss, misuse, and unauthorized disclosure, alteration, or destruction. Only authorized personnel have access to Personal Information you provide to us and each employee with access to Personal Information is obligated to maintain its integrity and confidentiality. Unfortunately, no data transmission can be guaranteed to be 100% secure or error free. If you have reason to believe that your interaction with us is no longer secure, you should immediately notify us in accordance with the section below entitled "Contacting Us." More Than A follows its Data Breach Incident Response Plan to respond to incidents that could compromise Personal Information.
Updating Your Personal Information. If you are a Member, you can update your Personal Information at any time by accessing your account. To do this, just click on the "My Account", "My Profile" or "My Desk" link.
Changes to the Privacy Policy. We reserve the right to change this Policy, and any changes to our Policy will become effective upon our posting of the revised Policy on the Services. Use of the Services following such changes constitutes your acceptance of the revised Policy then in effect. If we make changes to this Policy we will take reasonable steps to alert users of the Services that the Policy has been updated.
VII. YOUR PERSONAL DATA RIGHTS AND HOW TO CONTACT US
A. Your Data Choices
Applicable laws in some states in the United States and various countries and regions grant rights to individuals you might be entitled to. For information on the specific rights that apply in the European Economic Area, please read section VIII of this Policy. Regardless of the applicable law, More Than A offers to all US residents and to the residents of other jurisdictions that use and participate in our Services the following options:
- Opting out: Applicable laws provide individuals with the choice to opt out of three types of data processing activities: targeted advertising, sale of data, and automated decision-making with legal or similar effects. More Than A does not engage in f targeted advertising, does not sell Personal Information, and does not profile (as defined by applicable privacy laws) or undertake automated decision-making with legal or similar effects. Because we do not engage in those activities, we do not offer an option to opt out.
- Reviewing and transferring the information we have about you: You may review the Personal Information we have about you. However, we do have to take into account the privacy and the interests of others when releasing information, so this is not an absolute right. You might:
- Request a report. You have the choice to request access to information on what categories of Personal Information we have collected and processed about you.
- Request your data. You have the choice to request access to your Personal Information in a structured, commonly used, and machine-readable format (access), and you may have the right to transmit that data to another entity (portability).
- Request to correct. You have the choice to request that we rectify inaccurate or incomplete Personal Information concerning you.
- Deleting what we have: You have the choice to request that we delete the Personal Information we have about you. Please note that we may need to retain certain information because we are legally required to do so or in order to protect our legitimate interests. Once we process a deletion request, we may be unable to provide access or support to our Services. If you choose to delete your Personal information from our systems, this will also unsubscribe you from all More Than A Communications and delete other information such as your membership information, and reviews. You may re-subscribe to our communications at any time, but this will not restore your history if it has been permanently erased from our systems.
Note, that these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
You are entitled to exercise the options described above free from discrimination, as prohibited by applicable privacy laws. We typically do not charge any fees for exercising the choices described above, However, we may charge a reasonable fee for requests that are clearly unfounded, repetitive, or excessive. If we determine your request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
B. Submitting a Request
You may submit a request to us, or you may authorize another party to do so on your behalf using the mechanisms below. To make submitting request as easy as possible, we have provided the following method. You may submit requests to exercise your rights or any questions you may have about this Policy, or the practices of the Services through email: [email protected].
Further notes on making requests:
- Identity Verification. When you or an authorized agent on your behalf make a request, we will confirm your identity. We may reach out to you for additional information to verify your identity beyond what is included in your initial request. Information collected to verify your identity will never be used for any other purpose than to verify your identity to fulfill your request.
VIII. More Than A: EEA+ Privacy Policy
Who does this Section VIII apply to? This Section VIII (More Than A: EEA+ Privacy Policy) applies to users and other relevant individuals who are based in the European Economic Area and the UK (together, the EEA+; who we refer to as "EEA+ Users"). All references to "you", "your" or "user(s)" in this Section VIII (More Than A: EEA+ Privacy Policy) are references to such EEA+ Users only.
Why do we have a specific EEA+ Privacy Policy? Applicable data protection laws, including the EU General Data Protection Regulation and the so-called ‘UK GDPR’ (together, the GDPR), require us to provide information about our data processing practices and the rights available to relevant EEA+ Users.
Our representatives.
If you have any privacy questions or requests, you can easily submit them to More Than A through email: [email protected]
What do we mean by "Personal Information"? Under the GDPR, “Personal Data” refers to information about an identified or identifiable natural person. Throughout this Policy we use the term "Personal Information" to mean "Personal Data."
What are your rights in relation to your Personal Information? Under certain circumstances, by law you have the right to:
- Access. Request access to your Personal Information.
- Correction. Request correction of inaccurate or incomplete Personal Information that we hold about you.
- Erasure. Request erasure of your Personal Information.
- Objection. Object to our reliance on our Legitimate Interests (see below) as the legal basis of processing of your Personal Information
- Restriction. Request the restriction of processing of your Personal Information until we address your request, establish its accuracy or our reasons for processing it.
- Portability. Request the transfer of your Personal Information in a portable format to you or a third party of your choice.
- Withdraw consent. Withdraw your consent to any Processing that relies on it as a legal basis (see below).
How to exercise your rights? If you want to exercise any of the rights described above, you can do so by emailing: [email protected]
Typically, you will not have to pay a fee to access your Personal Information or to exercise any of the other rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with that request. We may need to request specific information from you to help us confirm your identity and expedite your request.
What Personal Information do we process? The bullets in Section I describes the categories of Personal Information that we collect and process.
Purposes for Processing. We have set out below, in a bulleted format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Information:
- Account creation, configuration, maintenance and performance
- Identity Data
- Contact Data
- Payment Data (if applicable)
- Example:
- To register your account on the Services, and to populate your Profile fields. To provide you with the core elements of the Services.
- To provide you with access to the additional features and functions of More Than A where either you have paid for a product, service, or sessions.
- Legal Basis: Contractual Necessity.
- Service Personalization
- Identity Data
- Contact Data
- Service Personalization Data
- Example: To personalize your experience with our services and within our communications and to recommend More Than A content, activities, features, and products that may be of interest.
- Legal Basis: Contractual Necessity.
- Troubleshooting and Service improvement
- Survey Data
- To track issues that might be occurring on our systems.
- To test and improve the Services.
- Legal Basis: Legitimate Interests. It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Services and associated systems and services.
- Anonymized Data creation
- Identity Data
- Contact Data
- Parental Data
- Service Personalization Data
- Communication Interaction Data
- Review and User Submitted Data
- Survey Data
- Example: We may create 'Anonymous Data' – this might include aggregated data such as statistical or demographic data.
- Legal Basis: Legitimate Interests.
- Newsletter and communications
- Identity Data
- Contact Data
- Service Personalization Data
- Communication Interaction Data
- Examples:
- To send you the newsletters and other communications that you have signed up for – and, where requested, to personalize the content of those communications to you.
- To inform you of upcoming sessions and services that we are hosting and to promote such sessions and services.
- To monitor your interaction with our communications (e.g., whether you have opened them).
- Legal Basis: Consent in respect of the both delivery of our newsletters and other communications (including event/webinar promotion), and monitoring your interactions with those communications.
- Parental consent management
- Parental Data
- Example: To send any parental consent request emails, and to engage in correspondence relating to the administration of parent’s children’s Profiles.
- Legal Basis: Compliance with Law.
- User submitted content
- Identity Data
- Review and User Submitted Data
- Example: As part of the Services, we post the reviews and posts and other content you submit to the Services.
- Legal Basis: Contractual Necessity.
- Running surveys and analyzing the responses
- Identity Data
- Contact Data
- Technical Data
- Survey Data
- Example: From time to time we run surveys to better understand our users, our areas of professional interest, and how to improve our Services.
- Legal Basis: Legitimate Interests. It is in our legitimate interests to better understand: our user-base, how to improve our Services, whether or not to develop new Services (and if so how), and the areas in which we do business generally.
- Sessions, Camp, and Services
- Identity Data
- Contact Data
- Session and Service Data
- Recording the session when the session is being recorded. We will notify you in advance. Sharing the recording with program or camp attendees
- Registering you for sessions and enabling your participation or attendance at these sessions (including communicating with you about the session for which you have signed up).
- Legal Basis: Contract. Legitimate Interests. It is in our legitimate interests to record and publish sessions that we host, and to ensure that only registered attendees attend such events and webinars.
- It is in our event partner organizations’ legitimate interests to receive a list of prospective attendees to gauge interest in the session.
Purpose limitation. We will only use your Personal Information for the purposes for which we collected it as listed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law (including the GDPR).
What happens when you do not provide necessary Personal Data or you withdraw consent? Where we need to process your Personal Information either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. Similarly, if we rely on your consent to process your Personal Information, you are entitled to withdraw your consent, but if you do, we may not be able to provide certain services or features to you. We will keep you informed of when your access to service or features depends on your consent.
Our newsletters. EEA+ Users who are Adult Members, and other EEA+ Users over the age of 18, can opt-in to receiving our newsletters. Please note, however, that you may continue to receive ‘service-related’ and other non-marketing emails from us, including notices of any updates to our Terms of Use or this Policy.
International transfers. We are headquartered in the United States. The Personal Information that we collect from and about you will be stored and processed in the United States and may be stored and processed in other countries outside of the EEA+. However, it is our policy to ensure that adequate contractual or other safeguards are applied to Personal Information transferred outside of the EEA+ where required by the GDPR. If you have questions about the safeguards applied to your Personal Information, you may contact us at: [email protected].
GLOSSARY
The capitalized terms used throughout this Policy have the following meanings:
Controller: The physical or legal person determining the purposes and means of collecting and processing Personal Information.
Privacy Policy or Policy: This legal document which discloses how we collect or receive, use, store, and manage Personal Information, and what your choices and rights are over your it.
Profile: The account profile you create to use our Services.
Services: More Than A website, https://brian-kops-s-school.teachable.com/ and all other applications, services, and websites that link to this Privacy Policy.
Terms of Use: Our disclaimer and agreement for users of our Services.
Members: Visitors who complete the membership registration process through our Services.
Personal Information: Information about an identified or identifiable natural person. It includes any information that can be used to identify (directly or indirectly) or contact a specific individual, such as the individual's name, postal address, email address, telephone number, or online identifier.
Site: More Than A website, https://brian-kops-s-school.teachable.com
Payment Services: Third-party service providers used by us to handle donations made by credit card and other payment transactions submitted to our Services.
Teen: Older kids for whom collecting parental consent is not required under applicable laws. In the U.S. a Teen would be a kid that is 13 or older yet under 18. This age range may vary in other countries and regions, but in all cases, an individual over 18 is not considered a Teen.
GDPR: The EU General Data Protection Regulation and the so-called ‘UK GDPR’