Last Updated July 8, 2022
Other online and offline interactions you have with us.
I. PERSONAL INFORMATION
A. “Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The types of information we collect depend on how you use our Services and may include:
Geolocation data (e.g., the time and date of your visit(s)); and
Education and/or professional background.
B. Collection of Personal Information
C. Use of Personal Information
We and our service providers use Personal Information for the following purposes:
Providing the functionality of the Services and fulfilling your requests.
To provide the Services’ functionality to you and providing you with related services;
To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments, or complaints, or when you request other information about our Services; and
To send administrative information to you, such as changes to our terms, conditions, and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials.
To send you marketing related emails, with information about our services, new products, and other news about the School or events we think may be of interest to you..
We will engage in this activity with your consent or where we have a legitimate interest.
Aggregating and/or anonymizing Personal Information. We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
Accomplishing our business purposes.
For data analysis, for example, to improve the efficiency of our Services;
For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
For managing our business, including administration on behalf of our shareholders and investors;
For developing new products and services;
For enhancing, improving, or modifying our Services, as well as undertaking quality and safety assurance measures;
For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; and
For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
D. Disclosure of Personal Information
We may disclose Personal Information:
To our third-party service providers, to facilitate services they provide to us such as data storage, email delivery, and other services.
You may elect to disclose Personal Information on message boards, chat, and other services which may be available to other users and the general public.
E. Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
To comply with applicable law and regulations. This may include laws outside your country of residence.
To cooperate with public and government authorities. To respond to a request or to provide information we believe is necessary or appropriate. These can include authorities outside your country of residence.
To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders or provide information we believe is important.
To legal and professional advisors. To seek advice in relation to our business.
For other legal reasons. To enforce our terms and conditions; and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
A. Other Information
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
Browser and device information;
Information collected through cookies and other technologies;
Demographic information and other information provided by you that does not reveal your specific identity; and
Information that has been aggregated in a manner such that it no longer reveals your specific identity.
B. Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
Your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the Apps) you are using. We use this information to ensure that the Services function properly.
C. Uses and Disclosures of Other Information
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
IV. CHOICES AND ACCESS
A. Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out or unsubscribe from receiving marketing-related emails from us by using the instructions found in our marketing related emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
B. How you can access, change, or delete your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to, or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
V. RETENTION PERIOD
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide the Services to you;
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
VI. THIRD PARTY SERVICES
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Meta, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Services.
VII. USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.
VIII. JURISDICTION AND CROSS-BORDER TRANSFER
We process and store information in the U.S. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. By using the Services, you consent to the processing of your information in the U.S. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.
IX. SENSITIVE INFORMATION
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., government-issued ID numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background, or trade union membership) on or through the Services or otherwise to us.
Jurisdiction Specific Information
I. EUROPEAN DATA PROTECTION
A. Rights under the GDPR, UK-GDPR, and other European data protection laws
If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include the right to:
Access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
The erasure of personal data that we hold about you in certain circumstances (for example, if it is no longer necessary for the purposes for which it was originally collected);
Request that we stop processing your personal data and/or stop sending you marketing communications;
Require us to correct any inaccurate or incomplete personal data;
Request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
B. Questions or Complaints
If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve using the Contacting Us information provided below, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article- 29/structure/data-protection-authorities/index_en.htm.
II. CALIFORNIA CONSUMER PRIVACY ACT
A. Rights under the CCPA
Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:
Access the categories and specific pieces of personal data we have collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom we have shared personal data;
Delete personal data under certain circumstances; and
Opt-out of the “sale” of personal data. However, we do not sell and have not sold Personal Information, as “sale” is defined in the CCPA.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
B. AUTHORIZED AGENTS
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include:
Proof of your registration with the California Secretary of State to conduct business in California; and/or
A power of attorney from the California resident pursuant to Probate Code sections 4121-4130.
If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:
Verify the resident’s own identity directly with us; or
Directly confirm with us that the resident provided you permission to submit the request.
III. Additional Information regarding Brazil
To the extent Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados or LGPD) covers your Personal Information, you have certain rights as specified in Article 18 of the LGPD:
Confirmation as to the existence of the processing of your Personal Information
Access to your Personal Information
Correction of incomplete, inaccurate, or out-of-date Personal Information
Anonymization, blocking, or deletion of Personal Information that is unnecessary, excessive, or being processed in noncompliance with the LGPD
Portability of your Personal information to another service or product provider, by means of your express request, pursuant with applicable regulations, and subject to commercial and industrial secrets
Deletion of Personal Information processed with your consent, except in certain situations as provided by the LGPD
Information about public and private entities with whom we have shared Personal Information
Information about the possibility of denying consent and the consequences of such denial
Revocation of your consent as provided by the LGPD
To make a request to exercise any right described above, or for other questions about this section, please contact us at SBLA Advisers Corp., 200 S Biscayne Blvd, 19th Floor Miami, Florida 33131, US, by email at firstname.lastname@example.org, or by phone at 1-855-860-3125. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as mailing address, telephone number and/or email address, in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.