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Privacy

HIGHBROW PRIVACY POLICY

Join Highbrow Limited (the “Company”) respects your privacy, is committed to protecting the privacy of its users, especially children, parents and legal guardians of children (“Parents”) and the Company’s video content licensors (“Content Providers” and collectively referred to herein as “Users”). The Company has published this Privacy Policy to explain how Company treats information you submit to Company. Please read this Privacy Policy carefully prior to your access to and/or use of the domain or domains managed by Company (currently www.joinhighbrow.com) (the “Site”) or downloading of and use of Company’s application for mobile or other devices, if applicable (the “App”) or otherwise using the services. All of the services, including but not limited to the Site and App, accessed from any devices or media now known or later developed are collectively referred to herein as the “Company Service.” If you do not agree to abide by both this Privacy Policy and the Company’s Terms of Service, which is incorporated herein by reference (the “Terms”), do not register, access or use the Site, App or any portion of the Company Service.

By submitting information to Company, either by using Company Service or registering on the Company Service, you are accepting the practices described in this Privacy Policy and the Terms. This Privacy Policy is governed by the Terms, which includes all disclaimers of warranties and limitation of liabilities. All capitalized terms not defined in this Privacy Policy will have the meaning ascribed to them in the Terms.

1. CHILDREN’S PRIVACY

On any part of the Company Service intended for and accessible to children, we do not collect personal contact information (such as full name, e-mail address, phone number or home address) from children without the consent of a parent or legal guardian (“Parent”), except in limited circumstances authorized by law. We will ask Parents to provide the Company with a username for their child and a date of birth in order to match the child with age-appropriate content. We do not ask for more personal information than is necessary for a child to participate in the Company Service.

When children interact with the Company Service, we passively collect some information, as described in further detail below, such as the type of computer or device used to access the Company Service, your operating system, web browser, and Internet protocol (IP) address. We will also use technologies like cookies, analytics programs (such as Google Analytics) and monitoring devices to provide functionality and support our operations, which will include tracking the frequency and manner with which each User interacts with the Company Service, and Users’ behavioral patterns. No personally identifiable information will be linked to such data. The Company collects the foregoing information from all Users interacting with the Company Service.

The Company will not ask a child under the age of 13 for more information than reasonable in order to provide that child with ability to request approval from a Parent. As stipulated by the Children’s Online Privacy Protection Act of 1998, as amended (“COPPA”), the Company may only ask for non-personally identifiable information, such as a username, password prior to their account creation approval by a Parent. The Company will also request Parent’s email address in order to attain approval and valid permission to use the Company Service.

We will track the following information when children interact with the Company Service:

  1. Which videos have been viewed, so the Company may generate progress reports;
  2. Whether videos are viewed, unviewed or partially viewed; and
  3. The duration of videos viewed for revenue calculation purposes.

We take steps to prevent children from posting or publicly disclosing personal contact information, including restricting children’s access to Parent-areas of the Company Service by requiring a separate password for Parents to access such areas. Children are only permitted to “view” the Company Service through a separate, child-oriented user interface, and cannot change or submit information without use of the Parents’ login credentials, which should be used only by Parents to avoid any unwanted disclosures.

In accordance with COPPA, Company does not knowingly collect or maintain personally identifiable information or non-personally-identifiable information on the Company Service from persons under 13 years of age. If you are under 13 years of age, then please do not use or access the Company Service at any time or in any manner without your Parent’s prior approval and registration. If Company learns that personally identifiable information of children under 13 years of age has been collected without verified parental consent, then Company will take the appropriate steps to delete this information and cancel the account.

Parents can ask us to update or delete their children’s information at any time by contacting info@joinhighbrow.com.

2. INFORMATION WE COLLECT

a. Registration Information

The Company will collect and process information voluntarily submitted by Parents and children aged 13 or older for registration purposes that could be directly associated with you without the aid of additional information, such as your full name, user name and password, phone number or e-mail address (“Registration Data”). We may also obtain information that you submit, or that we collect, that is not Registration Data but necessary for the proper functioning of our Service, such as the date regarding the start and end and the extent of your usage of the Company Service and your preferences, your browser, operating system, IP address, clickstream data and unique device identifiers (“Demographic and Usage Data”), in connection with the Company Service. Demographic and Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information. All information we collect from you is referred to as “Personal Information.”

b. Social Media

You may choose to share certain information. In order to participate in certain features, you may have to adjust your privacy settings and share more information. You may also choose to share your activity on other platforms, such as Facebook and Twitter. Please read the privacy policies of those platforms, because your activity published on those platforms will no longer be governed by the Company’s Privacy Policy.

If you connect to or otherwise integrate with the Company Service using a third party platform’s credentials, you authorize Company to collect your authentication information, such as your username, encrypted access credentials, and other information that may be available on or through your account with such third party platform. Such information, however collected by Company, may be stored and processed in the United Kingdom or any other country in which Company or its agents maintain facilities.

c. Information about your Computer or Device Collected by the Company

“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your web browser on your hard drive. Company may set and access cookies on your computer or mobile device to track and store preferential information about you. Company may gather anonymous information about users through cookie technology on an individual and aggregate level. Such information is used within Company internally and is only shared with third party advertisers, if any, on an aggregated or non-personally identifiable basis.

We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate Company Services. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. More info about cookies in this wikipedia article (http://en.wikipedia.org/wiki/HTTP_cookie).

When your children use Company Services, we collect certain non-personal information by placing and accessing cookies on the devices they are using. Cookies do not contain any personal information, so we do not use cookies (or other covert or non-consensual methods) to acquire contact information about your children or other users of the device.

This privacy policy does not cover any cookies used by third party systems in Company Services.

Web Beacons, also known as pixel tags and clear GIFs, (“Web Beacons”), are electronic images that allow a website to access cookies and help track marketing campaigns and general usage patterns of visitors to those websites. Web Beacons can recognize certain types of information, such as cookie numbers, time and date of a page view and a description of the page where the Web Beacons are placed. No personally identifiable information about you is shared with third parties through the use of Web Beacons on the Site. However, through Web Beacons, we may collect general information that will not personally identify you, such as: Internet browser, operating system, IP address, date of visit, time of visit and path taken through the Site.

Company may use Web Beacons internally to count visitors and recognize visitors through cookies. Access to cookies helps Company personalize the experience of Children, Parents and Content Providers when each visits the Company Service.

d. Advertisers; Information about your Computer or Device Collected by Third Parties

Company does not currently, but may in the future allow third parties to display advertisements on the Company Service. Company and these third parties may use tracking technologies, such as cookies and web beacons, to collect information about users who view or interact with these advertisements and utilize the Company Service. Company, its partners and/or advertisers may use third party servers to serve or present the advertisements that appear on the Company Service and to conduct research about the advertisements. Any of these ad servers may collect Demographic and Usage Information. Company cannot control the activities of such advertisers or web sites. PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH AD SERVERS.

If implemented, third party advertisements will be visible to Parents and Content Providers only. The Company does not permit advertising on the Company Service directed to children under 13 or where we have actual knowledge that a child is under 13. Advertisements will not be visible to children when properly logged in through a child account. To access the Parent or Content Provider view mode of the Company Service, a password set by the Parent or Content Provider must be entered in order to exit the child view mode.

e. Newsletters and Marketing

Company maintains a strict “no-spam” policy with respect to its communications to Users. If you register for the Company Service, you may receive Company’s newsletter, notices, special offers via email, and/or push notifications from the App, if applicable, unless you have requested otherwise at the time of registration or as set forth below.

You may unsubscribe from Company’s electronic newsletters, notices and/or special offers at any time by following the instructions contained at the end of each such email, or if a third-party vendor provides Company’s newsletter, in accordance with the instructions provided by such third party. While all efforts are made to insure this information is viewable in all email browsers, there may be cases where certain email browsers do not display the unsubscribe information correctly. If you are having problems unsubscribing please forward the entire newsletter here info@joinhighbrow.com with the word “UNSUBSCRIBE” in the Subject line and you will be removed within seven (7) business days. Please note that direct replies to any newsletter are processed by computer and are not always viewed by a human.

Company will use MailChimp or a similar service when communicating with Users by email. Emails may include HTML-formatted email messages to help Company determine your interest in and the effectiveness of such emails.

Information collected from Content Providers and Users will be aggregated and analyzed used for marketing purposes. However, once aggregated, no information will be personally identifiable and linked to any particular Content Provider or User.

f. Geographic Location

The Company automatically receives your location when you use the Company Service. We use various technologies to determine location, such as location services of the applicable operating system or browser and sensor data from your device that may, for example, provide information on nearby Wi-Fi- access points and cell towers. The Company will track Users’ locations in order to provide and distribute the best and most appropriate content. Your location will not be made public or shared with third parties, but used by the Company internally for analytics and content distribution purposes.

g. Financial Information

Your credit card information and other financial data that we need to process your payment are collected and stored by third party payment processors, and we may collect some limited information, such as your postal code and details of your transaction history. These third parties generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, and your card’s type, expiration date, and last four digits. By using the Company Service, you consent to any such transfer of information outside of your country, where data protection laws may be different. Company makes no representation or warranty with respect to any duty to permanently store any personal information you may provide. By using our Services and providing us with personal information, you waive any claims that may arise under your own or any other local or national laws, rules or regulations or international treaties. This Privacy Policy applies to your personal information for as long as your personal information is in our possession, even if you terminate or discontinue your use of the Company Service. Payment information will not be retained by the Company. However, the Company will retain your email address, name and other related information for six months, or until such information is no longer needed. Any information obtained by payment processors through the Company Service when you submit a payment will be retained by the third party in accordance with their practices. We suggest that you review our payment partner’s terms and privacy policy to understand how they manage and protect your personal information.

3. CHANGING, UPDATING OR DELETING PERSONAL INFORMATION

Parents and Content Providers may change, update or delete their information provided to the Company relating to Registration Data by changing profile settings on the Company Service at any time. Parents may change, update, or delete their children’s Registration Data or Personal Information at any time. You may request a change to or update the Registration Data you provide directly to Company by contacting Company via email at info@joinhighbrow.com (please include in the Subject line the words “Change in Registration Data”). You may also send us an email asking us to delete your account at info@joinhighbrow.com (please include in the Subject line the words “Delete My Account”). We will be happy to review, update or remove information as appropriate. We may still retain your information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your Personal Information will not be used for any other purpose.

Content Providers may change, update or delete limited information, including their username, password, payment information at any time. However Content Providers may only modify their licensed content and other data in accordance with their license agreement with the Company and with the Company’s prior consent.

Children under the age of 13 cannot edit their personal information at any time without Parental assistance through the Parent section of the Company Service.

4. USE OF PERSONAL INFORMATION

Company uses your Personal Information to identify you and to improve and customize the content you see via the Company Service, including but not limited to applying geo-filtering technologies. Your Personal Information may also be aggregated and used by Company for market research, project planning, business and operational development and improvement, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity, to enforce the Terms or any applicable rules, for other internal purposes, and as otherwise described to you at the time of collection. Company will obtain your consent for any use of your Personal Information beyond those set forth in this Privacy Policy and the original uses for which you provided your consent.

You agree that Company may use Personal Information about you to analyze Company Service usage, improve or customize Company’s Service, customize the Company Service’s content, and as otherwise set forth in this Privacy Policy. You also agree that Company may use your Personal Information to contact you. Unless you specifically opt out, you also agree that Company may use your Personal Information to contact you and deliver information to you that, in some cases, is targeted to your interests, such as administrative notices, product offerings, and communications relevant to your use of the Company Service. By accepting the Terms of Use and this Privacy Policy, you expressly agree to receive this information, unless you specifically opt out in applicable circumstances.

Any Personal Information or content that you voluntarily disclose on public portions of the Company Service, if applicable (such as discussion boards and public profile pages) may become publicly available and collected and used by others. Content Providers’ usernames may be displayed to other Users with their uploaded content. Content linked to social media accounts that Users voluntarily submit to the Company Service may be shared via the Internet and other media channels, and viewable by the general public.

5. DISCLOSURE OF PERSONAL INFORMATION

Except as expressly provided herein, Company does not share your Personal Information with any unrelated third parties absent your consent. Additionally, Company does not permit unrelated third parties to perform “reverse searches” whereby they could identify users from email addresses. In addition, the following describes some of the ways that your Personal Information may be disclosed in the normal scope of business to provide you with the Company Service:

  1. Profile. Company may post certain information as a part of your User Profile, which may be viewable by other Users and visitors to the site, including but not limited to your username. Company will not disclose your age, location, home address, email address, phone number, or full name in connection with your User Profile.
  2. External Service Providers. There are a number of separate services offered by third parties that Company refers to as external service providers that may be complementary to your use of the Company Service, including but not limited to the Company’s and its Content Providers’ external websites and/or social media platforms. If you choose to use these separate services, such as sharing a link to a social media site or clicking on any link that diverts you from the Company Service, then their use of your information on such external website is governed by their privacy policy. Similarly, Content Providers’ external websites and/or social media platform may contain links, including links to the Company Service. We do not make any representation or warranty with respect to any external site, its links or terms of service or privacy policies. With your consent, and for your convenience, Company may provide some of your Personal Information to an external service provider offering such services. To prevent Company’s disclosure of your personally identifiable information to an external service provider, you can decline such consent or simply not use their services. Because Company does not control the privacy practices of these third parties, you should always evaluate third party practices, including reviewing their terms of service and privacy policy, before deciding to use their services.
  3. Internal Service Providers. Company may use third parties that Company refers to as internal service providers to facilitate or outsource one or more aspects of Company’s business, products and Service that Company provides to you, including but not limited to payment processing, and, therefore, Company may provide some of your Personal Information directly to these internal service providers. In some instances, the internal service provider may collect information directly from you. In these cases, you will be notified of the involvement of the internal service provider. If you provide additional information to an internal service provider directly, then their use of your personally identifiable information is governed by their applicable privacy policy.

Notwithstanding the foregoing, Company reserves the right, and you authorize Company, to share or disclose your Personal Information, including, without limitation, any content, records or electronic communications of any kind, when Company determines, in its sole discretion, that the disclosure of your personally identifiable information is necessary to identify, contact, or bring legal action against you if:

  1. you are or may be violating the Terms of Service or this Privacy Policy;
  2. you are interfering with Company’s or a third party’s rights or property;
  3. you are violating any applicable law, rule or regulation;
  4. necessary or required by any applicable law, rule or regulation; and/or
  5. requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional or national emergency.

6. LINKS TO THIRD PARTIES

The Company Service may include links to third party websites, apps or services. Such links are not an endorsement by Company of those websites, apps and/or the products or services they offer. Third parties have different privacy policies, and Company is not responsible for the privacy practices of such third parties. If you click on a link to a third party website, app or service, Company encourages you to check the applicable privacy policy, as it may differ substantially from that of this Privacy Policy. Company makes no representations or warranties nor is Company responsible for the privacy policies of any third party. If you decide to access any third party links appearing on the Company Service, you do so at your own risk.

7. TRANSMISSIONS, SUBMISSIONS AND POSTINGS

Company welcomes the submission of comments, information and feedback regarding the Company Service. However, Company does not want to receive certain kinds of information from you, including any confidential or proprietary information, without prior written consent of Company. Although Company does not regularly review your transmissions, submissions or postings, Company reserves the right (but not the obligation), at its sole discretion and at any time, to edit, refuse to post or remove your transmissions, submissions or postings. You hereby acknowledge and agree that Company may review transmissions, submissions or postings made by you to determine, in its sole discretion, your compliance with the Terms, this Privacy Policy and any applicable Rules, and that Company shall have the unrestricted right to use such information for any purpose and without compensation to you.

8. SECURITY

Company takes a range of security measures designed to protect your Personal Information and keep it confidential (unless it is non-confidential by nature; for example, publicly-available information) and free from any unauthorized alteration. For example, the Company uses secure database storage, and transmits information via a secure URL. However, the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. The complete security of any Personal Information collected, stored or used by us cannot therefore be guaranteed. If your account is hacked, this may lead to unauthorized access to the your account and viewing of your Personal Information, so be careful to keep your account information secure. In the unlikely event that an unauthorized third party compromises Company’s security measures, Company will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information.

In addition, Company cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example, without limiting the foregoing, Company may be forced to disclose Personal Information to the government or third parties under certain circumstances or third parties may unlawfully intercept or access your transmissions or communications. Therefore, although Company uses industry standard practices to protect your privacy from malicious attacks and breaches, Company does not promise, and you should not expect, that your personally identifiable information or private communications will always remain private. However, Company shall use reasonable commercial and legal efforts to protect its Users’ information and to maintain the privacy and anonymity of its Users.

9. OTHER TERMS

To review other applicable terms and conditions that apply to this Privacy Policy, including, without limitation, intellectual property rights, disclaimer of warranties, limitation of liability, governing law, and resolving disputes, please review the Terms of Service.

10. CHANGES TO THIS PRIVACY POLICY

Company reserves the right, at its sole discretion, to update, amend and/or change this Privacy Policy without prior notice and at any time. Updates to this Privacy Policy will be posted here. You are encouraged to revisit this Privacy Policy from time to time in order to review any changes that have been made. Your continued use of the Company Service following the posting of any such changes shall automatically be deemed your acceptance of all changes.

11. SPECIAL NOTE TO INTERNATIONAL USERS

The Company is based and incorporated under the laws of England & Wales. However the Company Services is delivered worldwide. If you are a User accessing the Company Service from the United States of America, European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from the laws of England & Wales, please be advised that through your continued use of the Company Service, which is governed by the laws of England & Wales, this Privacy Policy, and our Terms, you are transferring your Personal Information to the England & Wales and you consent to that transfer.

12. IN THE EVENT OF MERGER, SALE, OR BANKRUPTCY

In the event that Company is acquired by or merged with a third party entity, or sells all or substantially all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the information and content we have received and collected from our Users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Information is treated, transferred, or used.

In the event of a merger, acquisition, sale of substantially all of its assets or change of control of Company, Personal Information collected by Company about you will be considered a business asset and will be transferred to the applicable new entity.

13. QUESTIONS OR CONCERNS

If you have questions, comments, concerns or feedback regarding this Privacy Policy or the Terms of Use, please contact us via email at info@joinhighbrow.com.

  1. Updated: February 15, 2017