개
인정
보
처
리
방
침
1
개
인정
보
처
리
방
침
제
1
조
(
목
적
)
이
약
관
은
팀
러
너
스
(
이
하
'
회
사
')
가
제
공
하
는
피
카
부
스
튜
디
오
(
이
하
'
서
비
스
')
의
이
용
조
건
과
회
원의
권
리
,
의
무
,
책
임
사
항
,
개
인정
보
보
호
등
기
타
필
요
한
사
항
을
규
정
하
는
것
을
목
적
으
로
합
니다
.
제
2
조
(
개
인정
보
처
리
방
침
)
회
사
는
이
약
관
을
바
탕
으
로
개
인정
보
처
리
방
침
을
마
련
하
고
있
으
며
,
회
원의
개
인정
보
수
집
,
이
용
,
보
호
에
대
한
내
용은
개
인정
보
처
리
방
침
에
따
릅
니다
.
제
3
조
(
개
인정
보
의
수
집
및
이
용
목
적
)
회
사
는
다
음
과
같
은
목
적
으
로
개
인정
보
를
수
집
및
이
용
합
니다
:
회
원
가
입
및
관
리
재
화
또
는
서
비
스
제
공
고
객
만
족
을
위
한
서
비
스
품
질
개
선
및
개
발
고
충
처
리
마
케
팅
및
광고
에
의
활
용
제
4
조
(
수
집
되
는
항
목
)
회
사
는
다
음
과
같
은
항
목
을
수
집
합
니다
:
1.
회
원
가
입
시
수
집
사
항
:
이
메
일
휴
대
폰
번
호
2. AI
결과
물
생성
시
수
집
사
항
:
이
용
자
사
진
개
인정
보
처
리
방
침
2
3.
유
료
재
화
결
제
시
수
집
사
항
:
신
용
카
드
결
제
시
:
카
드
사
명
,
카
드
번
호
,
이
메
일
,
생
년
월
일
,
사
업
자
등
록
번
호
계
좌
이
체
시
:
예
금
주
명
,
계
좌
번
호
,
계
좌
보
유은
행
휴
대
전
화
번
호
결
제
시
:
휴
대
전
화
번
호
,
통
신
사
정
보
4.
고
충
처
리
시
수
집
사
항
:
이
용
자
로
부
터
필
요
한
항
목
및
해
당
고
충
처
리
에
필
요
한
별
개
항
목
을
수
집
및
처
리
5.
서
비
스
이
용
과
정
에
서
자
동
으
로
수
집
되
는
항
목
:
IP
주
소
쿠
키
서
비
스
이
용
기
록
(
방
문
및
이
용
기
록
,
불
량
이
용
기
록
등
)
기기
정
보
(
휴
대
폰
모
델
명
, OS
명
및
버
전
정
보
)
광고
식
별
자
제
5
조
(
개
인정
보
의
처
리
및
보
유
기
간
)
회
사
는
개
인정
보
의
처
리
및
보
유
기
간
을
다
음
과
같
이
정
하
고
있
습
니다
:
1.
회
사
는
개
인정
보
의
수
집
및
이
용
목
적이
달
성
되
거
나
,
이
용
자
가
서
비
스
를
탈
퇴
또
는
이
용
자
격
을
상
실
할
경
우
에
는
별
도
의
요
청
이
없
더
라
도
수
집
된
이
용
자
의
정
보
를
지
체
없
이
삭
제
및
파
기
합
니다
.
다
만
,
회
원
탈
퇴
또
는
이
용
자
격
상
실
에
도
불
구
하
고
다
음의
정
보
에
대
해
서
는
아
래
의
이
유
로
보
존
합
니다
:
관계
법
령
위
반
에
따
른
수
사
조
사
등
이
진
행
중
인
경
우
에
는
해
당
수
사
·
조
사
종
료
시
까
지
앱
이
용
에
따
른
채
권
·
채
무
관계
잔
존
시
에
는
해
당
채
권
·
채
무
관계
정
산
시
까
지
회
사
가
이
용
약
관
에
따
라
서
비
스
이
용
계
약
을
해
지
한
경
우
,
부
정
한
재
가
입
및
서
비
스
이
용을
방
지
하
기
위
하
여
서
비
스
2.
전
항
에
도
불
구
하
고
회
사
는
다
음의
사
유
에
해
당
하
는
경
우
에
는
해
당
기
간
종
료
시
까
지
보
존
합
니다
:
서
비
스
이
용
관
련
개
인정
보
(
로
그
기
록
): "
통
신
비
밀
보
호
법
"
상
보
존
기
간
인
3
개
월
계
약
또
는
청
약
철
회
등
에
관
한
기
록
및
대
금
결
제
및
재
화
등
의
공
급
에
관
한
기
록
: "
전
자
상
거
래
등
에
서
의
소
비
자
보
호
에
관
한
법
률
"
상
보
존
기
간
인
5
년
개
인정
보
처
리
방
침
3
표
시
광고
에
관
한
기
록
: "
전자
상
거
래
등
에
서
의
소
비
자
보
호
에
관
한
법
률
"
상
보
존
기
간
인
6
개
월
세
법
이
규
정
하
는
모
든
거
래
에
관
한
장
부
및
증
빙
서
류
: "
국
세
기
본법
"
상
보
존
기
간
인
5
년
이
외의
내
용은
개
인정
보
처
리
방
침
에
따
릅
니다
.
제
6
조
(
개
인정
보
보
호
책
임자
)
개
인정
보
보
호
책
임자
의
연
락
처
는
다
음
과
같
습
니다
:
성
명
:
정
승
진
직
책
:
대
표
이
사
연
락
처
: 02-6953-6510
이
메
일
: admin@learners.company
위의
내
용은
팀
러
너
스
(
이
하
'
회
사
')
의
피
카
부
스
튜
디
오
서
비
스
이
용
약
관
에
대
한
요
약
입
니다
.
전
체
내
용은
서
비
스
이
용
시
해
당
약
관
을
참
고
하
시
기
바
랍
니다
.
Privacy Policy 1
Privacy Policy
PRIVACY POLICY
Last updatedAugust 01, 2023
This privacy notice forTeam Learners Inc.("Company," "we," "us," or "our"),
describes how and why we might collect, store, use, and/or share ("process") your
information when you use our services ("Services"), such as when you:
Visit our websiteathttps://peekaboo.style, or any website of ours that links to
this privacy notice
Download and useour mobile application(Studio Peekaboo),or any other
application of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns?Reading this privacy notice will help you understand your
privacy rights and choices. If you do not agree with our policies and practices, please
do not use our Services. If you still have any questions or concerns, please contact
us atadmin@learners.company.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
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. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
10. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Privacy Policy 2
1. WHAT INFORMATION DO WE
COLLECT?
Personal information you disclose to us
In Short:We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when youregister
on the Services,express an interest in obtaining information about us or our
products and Services, when you participate in activities on the Services, or
otherwise when you contact us.
Personal Information Provided by You.The personal information that we collect
depends on the context of your interactions with us and the Services, the choices
you make, and the products and features you use. The personal information we
collect may include the following:
email addresses
photos uploaded by you
Sensitive Information.We do not process sensitive information.
Payment Data.We may collect data necessary to process your payment if you
make purchases, such as your payment instrument number, and the security code
associated with your payment instrument. All payment data is stored
by__________. You may find their privacy notice link(s) here:__________.
Application Data.If you use our application(s), we also may collect the following
information if you choose to provide us with access or permission:
Geolocation Information.We may request access or permission to track location-
based information from your mobile device, either continuously or while you are
using our mobile application(s), to provide certain location-based services. If you
wish to change our access or permissions, you may do so in your device's
settings.
Mobile Device Access.We may request access or permission to certain features
from your mobile device, including your mobile device'scamera,contacts,sms
Privacy Policy 3
messages,storage,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 automatically collect device information (such as your
mobile device ID, model, and manufacturer), operating system, version
information and system configuration information, device and application
identification numbers, browser type and version, hardware model Internet
service provider and/or mobile carrier, and Internet Protocol (IP) address (or
proxy server). If you are using our application(s), we may also collect information
about the phone network associated with your mobile device, your mobile
device’s operating system or platform, the type of mobile device you use, your
mobile device’s unique device ID, and information about the features of our
application(s) you accessed.
Push Notifications.We may request to send you push notifications regarding
your account or certain features of the application(s). If you wish to opt out from
receiving these types of communications, you may turn them off in your device's
settings.
This information is primarily needed to maintain the security and operation of our
application(s), for troubleshooting, and for our internal analytics and reporting
purposes.
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.
Information automatically collected
In Short:Some information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when you visit our
Services.
We automatically collect certain information when you visit, use, or navigate the
Services. 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 you use our Services, and other technical information. This information is
primarily needed to maintain the security and operation of our Services, and for our
internal analytics and reporting purposes.
The information we collect includes:
Privacy Policy 4
Log and Usage Data.Log and usage data is service-related, diagnostic, usage,
and performance information our servers automatically collect when you access
or use our Services and which we record in log files. Depending on how you
interact with us, this log data may include your IP address, device information,
browser type, and settings and information about your activity in the
Services(such as the date/time stamps associated with your usage, pages and
files viewed, searches, and other actions you take such as which features you
use), device event information (such as system activity, error reports (sometimes
called"crash dumps"), and hardware settings).
Device Data.We collect device data such as information about your computer,
phone, tablet, or other device you use to access the Services. Depending on the
device used, this device data may include information such as your IP address
(or proxy server), device and application identification numbers, location,
browser type, hardware model, Internet service provider and/or mobile carrier,
operating system, and system configuration information.
Location Data.We collect location data such as information about your device's
location, which can be either precise or imprecise. How much information we
collect depends on the type and settings of the device you use to access the
Services. For example, we may use GPS and other technologies to collect
geolocation data that tells us your current location (based on your IP address).
You can opt out of allowing us to collect this information either by refusing
access to the information or by disabling your Location setting on your device.
However, if you choose to opt out, you may not be able to use certain aspects of
the Services.
2. HOW DO WE PROCESS YOUR
INFORMATION?
In Short:We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your
consent.
We process your personal information for a variety of reasons, depending on
how you interact with our Services, including:
To facilitate account creation and authentication and otherwise manage
user accounts.We may process your information so you can create and log in
Privacy Policy 5
to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user.We may process
your information to provide you with the requested service.
To respond to user inquiries/offer support to users.We may process your
information to respond to your inquiries and solve any potential issues you might
have with the requested service.
To send administrative information to you.We may process your information
to send you details about our products and services, changes to our terms and
policies, and other similar information.
Tofulfilland manage your orders.We may process your information
tofulfilland manage your orders, payments, returns, and exchanges made
through the Services.
To enable user-to-user communications.We may process your information if
you choose to use any of our offerings that allow for communication with another
user.
To save or protect an individual's vital interest.We may process your
information when necessary to save or protect an individual’s vital interest, such
as to prevent harm.
To improve the image quality of AI photos and make photos that
customers are more satisfied with. We use the photos you upload for
research purposes only as a reference to improve the AI photo model training
output. This information is guaranteed not to be leaked outside, provided to third
parties, or exposed to other customers.
3. WHAT LEGAL BASES DO WE RELY ON
TO PROCESS YOUR INFORMATION?
In Short:We only process your personal information when we believe it is
necessary and we have a valid legal reason (i.e.,legal basis) to do so under
applicable law, like with your consent, to comply with laws, to provide you with
services to enter into orfulfillour contractual obligations, to protect your rights, or
tofulfillour legitimate business interests.
If you are located in the EU or UK, this section applies to you.
Privacy Policy 6
The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases to process your
personal information:
Consent.We may process your information if you have given us permission
(i.e.,consent) to use your personal information for a specific purpose. You can
withdraw your consent at any time. Learn more aboutwithdrawing your consent.
Performance of a Contract.We may process your personal information when
we believe it is necessary tofulfillour contractual obligations to you, including
providing our Services or at your request prior to entering into a contract with
you.
Legal Obligations.We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate with a
law enforcement body or regulatory agency, exercise or defend our legal rights,
or disclose your information as evidence in litigation in which we are involved.
Vital Interests.We may process your information where we believe it is
necessary to protect your vital interests or the vital interests of a third party, such
as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission
(i.e.,express consent) to use your personal information for a specific purpose, or in
situations where your permission can be inferred (i.e.,implied consent). You
canwithdraw your consentat any time.
In some exceptional cases, we may be legally permitted under applicable law to
process your information without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be
obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to
assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of
kin
Privacy Policy 7
If we have reasonable grounds to believe an individual has been, is, or may be
victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise
the availability or the accuracy of the information and the collection is reasonable
for purposes related to investigating a breach of an agreement or a
contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules
of the court relating to the production of records
If it was produced by an individual in the course of their employment, business,
or profession and the collection is consistent with the purposes for which the
information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL
INFORMATION?
In Short:We may share information in specific situations described in this section
and/or with the followingthird parties.
Wemay need to share your personal information in the following situations:
Business Transfers.We may share or transfer your information in connection
with, or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
Offer Wall.Our application(s) may display a third-party hosted"offer wall."Such
an offer wall allows third-party advertisers to offer virtual currency, gifts, or other
items to users in return for the acceptance and completion of an advertisement
offer. Such an offer wall may appear in our application(s) and be displayed to
you based on certain data, such as your geographic area or demographic
information. When you click on an offer wall, you will be brought to an external
website belonging to other persons and will leave our application(s). A unique
identifier, such as your user ID, will be shared with the offer wall provider in order
to prevent fraud and properly credit your account with the relevant reward.
Privacy Policy 8
5. HOW LONG DO WE KEEP YOUR
INFORMATION?
In Short:We keep your information for as long as necessary tofulfillthe purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements).No purpose
in this notice will require us keeping your personal information for longer thanthe
period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either delete oranonymizesuch information, 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.
6. HOW DO WE KEEP YOUR
INFORMATION SAFE?
In Short:We aim to protect your personal information through a system
oforganizationaland technical security measures.
We have implemented appropriate and reasonable technical
andorganizationalsecurity measures designed to protect the security of any
personal information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or information
storage technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or otherunauthorizedthird parties will not be
able to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information,
transmission of personal information to and from our Services is at your own risk.
You should only access the Services within a secure environment.
Privacy Policy 9
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:In some regions, such asthe European Economic Area (EEA), United
Kingdom (UK), and Canada, 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.
In some regions (likethe EEA, UK, and Canada), 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. You can make such a request by contacting
us by using the contact details provided in the section"HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?"below.
We will consider and act upon any request in accordance with applicable data
protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to yourMember State
data protection authorityorUK data protection authority.
If you are located in Switzerland, you may contact theFederal Data Protection and
Information Commissioner.
Withdrawing your consent:If we are relying on your consent to process your
personal information,which may be express and/or implied consent depending on
the applicable law,you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the contact details
provided in the section"HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?"belowor updating your preferences.
However, please note that this will not affect the lawfulness of the processing before
its withdrawal nor,when applicable law allows,will it affect the processing of your
personal information conducted in reliance on lawful processing grounds other than
consent.
Opting out of marketing and promotional communications:You can unsubscribe
from our marketing and promotional communications at any time byor by contacting
us using the details provided in the section"HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?"below. You will then be removed from the marketing lists. However,
we may still communicate with you — for example, to send you service-related
Privacy Policy 10
messages that are necessary for the administration and use of your account, to
respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
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, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our legal terms and/or comply with applicable legal
requirements.
If you have questions or comments about your privacy rights, you may email us
atadmin@learners.company.
8. CONTROLS 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. At this stage no uniform technology standard forrecognizingand
implementing DNT signals has beenfinalized. 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 notice.
9. DO CALIFORNIA RESIDENTS HAVE
SPECIFIC PRIVACY RIGHTS?
In Short:Yes, if you are a resident of California, you are granted specific rights
regarding access to your personal information.
Privacy Policy 11
California Civil Code Section 1798.83, also known as the"Shine The Light"law,
permits our users who are California residents to request and obtain from us, once a
year and free of charge, information about categories of personal information (if any)
we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age, reside in California, and have a registered account
with Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact us
using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our
systems (e.g.,backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a"resident"as:
(1) every individual who is in the State of California for other than a temporary or
transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All other individuals are defined as"non-residents."
If this definition of"resident"applies to you, we must adhere to certain rights and
obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve
(12) months:
Category Examples Collected
A. Identifiers
Contact details, such as real name, alias, postal
address, telephone or mobile contact number,
unique personal identifier, online identifier,
Internet Protocol address, email address, and
account name
YES
B. Personal Name, contact information, education, NO
Privacy Policy 12
information categories
listed in the California
Customer Records
statute
employment, employment history, and financial
information
C. Protected
classification
characteristics under
California or federal
law
Gender and date of birth YES
D. Commercial
information
Transaction information, purchase history,
financial details, and payment information
YES
E. Biometric
information
Fingerprints and voiceprints NO
F. Internet or other
similar network
activity
Browsing history, search history, onlinebehavior,
interest data, and interactions with our and other
websites, applications, systems, and
advertisements
NO
G. Geolocation data Device location NO
H. Audio, electronic,
visual, thermal,
olfactory, or similar
information
Images and audio, video or call recordings
created in connection with our business activities
NO
I. Professional or
employment-related
information
Business contact details in order to provide you
our Services at a business level or job title, work
history, and professional qualifications if you
apply for a job with us
NO
J. Education
Information
Student records and directory information NO
K. Inferences drawn
from other personal
information
Inferences drawn from any of the collected
personal information listed above to create a
profile or summary about, for example, an
individual’s preferences and characteristics
NO
L. Sensitive Personal
Information
NO
We will use and retain the collected personal information as needed to provide the
Services or for:
Category A -As long as the user has an account with us
Category C -As long as the user has an account with us
Privacy Policy 13
Category D -As long as the user has an account with us
We may also collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in the
context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this
privacy notice.
You may contact usby email atadmin@learners.company,or by referring to the
contact details at the bottom of this document.
If you are using anauthorizedagent to exercise your right to opt out we may deny a
request if theauthorizedagent does not submit proof that they have been
validlyauthorizedto act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Each service provider is a
for-profit entity that processes the information on our behalf, following the same strict
privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This
is not considered to be"selling"of your personal information.
Team Learners Inc.has not disclosed, sold, or shared any personal information to
third parties for a business or commercial purpose in the preceding twelve (12)
months.Team Learners Inc.will not sell or share personal information in the future
belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal
information, subject to certain exceptions provided by law, such as (but not limited
to) the exercise by another consumer of his or her right to free speech, our
Privacy Policy 14
compliance requirements resulting from a legal obligation, or any processing that
may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a
business purpose;
the categories of third parties to whom the personal information was sold,
shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal
information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or to
re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are
the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we can match
it with information you have previously provided us. For instance, depending on the
type of request you submit, we may ask you to provide certain information so that we
can match the information you provide with the information we already have on file,
or we may contact you through a communication method (e.g.,phone or email) that
you have previously provided to us. We may also use other verification methods as
the circumstances dictate.
Privacy Policy 15
We will only use personal information provided in your request to verify your identity
or authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. However, if we
cannot verify your identity from the information already maintained by us, we may
request that you provide additional information for the purposes of verifying your
identity and for security or fraud-prevention purposes. We will delete such
additionally provided information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the information.
You can designate anauthorizedagent to make a request under the CCPA on
your behalf. We may deny a request from anauthorizedagent that does not
submit proof that they have been validlyauthorizedto act on your behalf in
accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal
information to third parties. Upon receiving an opt-out request, we will act upon
the request as soon as feasibly possible, but no later than fifteen (15) days from
the date of the request submission.
To exercise these rights, you can contact usby email
atadmin@learners.company,or by referring to the contact details at the bottom of
this document. If you have a complaint about how we handle your data, we would
like to hear from you.
10. DO VIRGINIA RESIDENTS HAVE
SPECIFIC PRIVACY RIGHTS?
In Short:Yes, if you are a resident of Virginia, you may be granted specific rights
regarding access to and use of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer"means a natural person who is a resident of the Commonwealth acting
only in an individual or household context. It does not include a natural person acting
Privacy Policy 16
in a commercial or employment context.
"Personal data"means any information that is linked or reasonably linkable to an
identified or identifiable natural person."Personal data"does not include de-
identified data or publicly available information.
"Sale of personal data"means the exchange of personal data for monetary
consideration.
If this definition"consumer"applies to you, we must adhere to certain rights and
obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how
you interact withTeam Learners Inc.and our Services. To find out more, please visit
the following links:
Personal data we collect
How we use your personal data
When and with whom we share your personal data
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects ("profiling")
Team Learners Inc.has not sold any personal data to third parties for business or
commercial purposes.Team Learners Inc.will not sell personal data in the future
belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this
privacy notice.
You may contact us by email atadmin@learners.company,by submitting adata
subject access request, or by referring to the contact details at the bottom of this
document.
Privacy Policy 17
If you are using anauthorizedagent to exercise your rights, we may deny a request
if theauthorizedagent does not submit proof that they have been
validlyauthorizedto act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to
verify you and your consumer's request. If you submit the request through
anauthorizedagent, we may need to collect additional information to verify your
identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases,
within forty-five (45) days of receipt. The response period may be extended once by
forty-five (45) additional days when reasonably necessary. We will inform you of any
such extension within the initial 45-day response period, together with the reason for
the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision
and reasoning behind it.If you wish to appeal our decision, please email us
atadmin@learners.company. Within sixty (60) days of receipt of an appeal, we will
inform you in writing of any action taken or not taken in response to the appeal,
including a written explanation of the reasons for the decisions. If your appeal if
denied, you may contact theAttorney General to submit a complaint.
11. DO WE MAKE UPDATES TO THIS
NOTICE?
In Short:Yes, we will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice 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 notice, 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 notice frequently
to be informed of how we are protecting your information.
Privacy Policy 18
12. HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?
If you have questions or comments about this notice, you maycontact our Data
Protection Officer (DPO),Sejungjin Jung,by email atadmin@learners.company, or
contact us by post at:
Team Learners Inc.
Sejungjin Jung
6, Nonhyeon-ro 76-gil
Gangnam-gu,Seoul06224
South Korea
13. HOW CAN YOU REVIEW, UPDATE, OR
DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that information, or
delete it.To request to review, update, or delete your personal information, pleasefill
out and submit adata subject access request.
