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Privacy Policy

Updated on July 23, 2025

Effective Date: July 23, 2025

This Privacy Policy constitutes a binding agreement between you and omgadrian inc. ("Company," "we," "us," or "our"), regarding the collection, use, processing, storage, and disclosure of your personal information. This Privacy Policy governs all information practices related to your access to and use of the Company website, mobile applications, and any other online or mobile services that reference or incorporate this Privacy Policy (collectively, the "Services").

IMPORTANT NOTICE: BY ACCESSING OR USING THE SERVICES, YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, YOU MUST IMMEDIATELY CEASE ALL USE OF THE SERVICES AND REFRAIN FROM ACCESSING THEM IN THE FUTURE.

1.
Article I: Definitions and Scope

For purposes of this Privacy Policy, the following definitions shall apply:

"Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, as defined under applicable privacy laws.

"Processing" means any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.

"Services" means all websites, mobile applications, software, platforms, content, features, and services provided by Company that reference this Privacy Policy.

"Third Parties" means individuals, companies, or entities that are not Company, its affiliates, or its authorized service providers.

This Privacy Policy applies exclusively to information collected through the Services and does not govern information collected through any other means or channels, including offline interactions, unless explicitly stated otherwise.

2.
Article II: Information Collection Practices
Section 2.1: Categories of Information Collected

The Company collects Personal Information through multiple channels and methods as part of providing the Services. The specific types and categories of information collected depend upon your interactions with the Services, your account settings, and the features you choose to utilize.

Section 2.2: Information You Voluntarily Provide

When you interact with the Services, you may voluntarily provide various types of Personal Information directly to us. This voluntary provision of information occurs through multiple touchpoints and interactions, including but not limited to:

  • Account registration and profile creation processesΒ 
  • Purchase transactions and billing arrangementsΒ 
  • Customer service inquiries and support requestsΒ 
  • Participation in surveys, contests, sweepstakes, or promotional activitiesΒ 
  • Submission of reviews, comments, or user-generated contentΒ 
  • Communication with us via email, online forms, or other channelsΒ 
  • Upload of content or materials to the ServicesΒ 
  • Enrollment in classes or educational programs

The specific categories of Personal Information you may provide include, without limitation: email addresses, full names, login credentials and authentication information, comprehensive billing and payment information (including credit card numbers, verification codes, billing addresses, and expiration dates), telephone numbers, transaction histories and purchase records, customer service interaction records, demographic information and profile preferences, user-generated content and communications, class enrollment data and academic progress, voice recordings when utilizing speech-to-text features, and any additional information you voluntarily choose to share in connection with your use of the Services.

Section 2.3: Information About Third Parties

In certain circumstances, you may provide Personal Information about third parties, such as when purchasing gift subscriptions or requesting that the Services be provided to individuals other than yourself. When you provide such third-party information, you represent and warrant that you have obtained all necessary consents and authorizations from such third parties for the collection, use, and processing of their Personal Information in accordance with this Privacy Policy. You further agree to indemnify and hold harmless Company from any claims, damages, or liabilities arising from your provision of third-party Personal Information without proper authorization.

Section 2.4: Automated Information Collection

The Company employs various automated technologies and methodologies to collect information about your use of the Services. This automated collection occurs continuously during your interactions with our platforms and includes comprehensive tracking of user behavior, technical specifications, and usage patterns.

For website interactions, we automatically collect and analyze extensive technical and behavioral data, including but not limited to: Internet Protocol (IP) addresses and geolocation data derived therefrom, browser types, versions, and configurations, operating system information and device specifications, software and hardware attributes including unique device identifiers, referral sources and exit destinations, clickstream data and navigation patterns, page views and content consumption metrics, session duration and frequency of visits, timestamps and date information for all activities, content viewing histories and engagement metrics, error logs and technical diagnostic information, and search queries and interaction data.

When you utilize our mobile applications, we collect similar comprehensive data sets specifically related to mobile device usage, including device identifiers and hardware specifications, mobile operating system versions and configurations, Internet service provider information, application version and update histories, mobile-specific usage patterns and behaviors, location-derived information, and mobile network connectivity data.

Section 2.5: Location Information

Through your use of the Services, we may collect various forms of location-related information. This includes general geographic location data derived from IP addresses, city and state information associated with your connection, postal codes linked to your geographic area, and any location information you voluntarily provide. We do not collect precise GPS coordinates or real-time location tracking unless you explicitly enable such features through your device settings.

Section 2.6: Social Media and Third-Party Platform Integration

When you choose to access the Services through third-party platforms or social networking services, you may authorize us to collect and store specific information from your social media profiles and accounts. This integration is entirely optional and subject to your explicit authorization through the third-party platform's authentication and permission systems.

The scope of information we may collect through such integrations includes your public profile information, social networking identification data, profile photographs and images, social connections and friend lists, activity feeds and status updates, and preference data and interests, all subject to the privacy settings and permissions you have configured on the respective third-party platforms. You acknowledge and agree that if you enable social sharing features, your activities and interactions with the Services may be visible to your social network connections according to the privacy policies and terms of service of those third-party platforms.

Section 2.7: Third-Party Data Sources

To enhance and supplement the information we collect directly from you, we may obtain additional Personal Information from various third-party sources, including business partners, data brokers, marketing organizations, research firms, analytics providers, and other commercial data sources. This supplemental information may include demographic data, behavioral insights, preference indicators, statistical information, and other data points that help us better understand your interests and provide more relevant services. All such third-party data collection and sharing is conducted in accordance with applicable privacy laws and the terms of our agreements with these data sources.

3.
Article III: Information Use and Processing
Section 3.1: Primary Purposes of Processing

The Company processes your Personal Information for multiple legitimate business purposes, each of which is essential to providing, maintaining, and improving the Services. Our processing activities are conducted in accordance with applicable privacy laws and are limited to purposes that are compatible with the original collection purposes or for which we have obtained your explicit consent.

Section 3.2: Service Provision and Account Management

We process Personal Information to deliver the core functionalities of the Services, including account creation and maintenance, user authentication and security verification, content delivery and personalization, payment processing and transaction management, customer support and technical assistance, and ongoing service improvements and updates. This processing is necessary to fulfill our contractual obligations to you and to ensure the proper functioning of the Services.

Section 3.3: Communication and Customer Relations

Personal Information is processed to facilitate various forms of communication between Company and our users, including service-related notifications and updates, billing and account information, customer support correspondence, educational content and program information, and administrative communications regarding policy changes or service modifications. We maintain detailed records of these communications to ensure quality service delivery and regulatory compliance.

Section 3.4: Marketing and Promotional Activities

Subject to applicable legal requirements and your consent preferences, we may process Personal Information for marketing and promotional purposes, including the development and delivery of targeted advertising campaigns, promotional communications about new products and services, personalized content recommendations, market research and analysis, and customer engagement initiatives. You maintain the right to opt out of marketing communications at any time through the mechanisms provided in such communications or by contacting us directly.

Section 3.5: Analytics and Business Intelligence

We process Personal Information to generate business intelligence and analytical insights that help us understand user behavior, improve service quality, and make informed business decisions. This includes usage pattern analysis, performance metrics evaluation, user experience optimization, content effectiveness measurement, and strategic business planning. Such processing may involve the use of artificial intelligence, machine learning algorithms, and large language model technologies.

Section 3.6: Legal Compliance and Risk Management

Personal Information may be processed as necessary to comply with legal obligations, enforce our Terms of Service and other agreements, protect the rights and safety of our users and the public, prevent fraud and unauthorized access, respond to legal processes and government requests, and defend against legal claims or disputes. This processing is essential for maintaining the integrity and security of the Services and protecting all stakeholders' interests.

Section 3.7: Artificial Intelligence and Machine Learning

The Company may employ artificial intelligence, machine learning algorithms, and large language model technologies to process Personal Information for various purposes, including content personalization, user experience enhancement, predictive analytics, automated customer support, and service optimization. When artificial intelligence technologies are used, we implement appropriate safeguards to ensure fairness, accuracy, and transparency in automated decision-making processes that may significantly affect you.

4.
Article IV: Cookies and Similar Technologies

To collect the information described in the automated information collection section above, we and our service providers use Internet server logs, local storage, cookies, tracking pixels, and other similar tracking technologies, collectively referred to as "Tracking Technologies." We use these technologies to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.

Section 4.1: Technology Overview and Functionality

Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to recognize your computer, store your preferences and settings, understand the web pages of the Services you have visited, enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests, perform searches and analytics, and assist with security and administrative functions.

Section 4.2: Types and Purposes of Tracking Technologies

We employ different categories of Tracking Technologies for various purposes, including essential functionality cookies that are necessary for basic service operation, performance and analytics cookies that help us understand service usage, functionality cookies that remember your preferences and settings, and advertising cookies that enable targeted marketing and personalization.

Section 4.3: Third-Party Tracking

Third-party partners may also place Tracking Technologies on your device through the Services for analytics, advertising, and other purposes. These third parties operate under their own privacy policies, and we encourage you to review their practices.

Section 4.4: Cookie Management and Control

As we adopt additional technologies, we may also gather information through other methods. You can change your settings to notify you when a cookie is being set or updated or to block cookies altogether. Please consult the "Help" section of your browser for more information, such as Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari. You acknowledge that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services. For more comprehensive information about our use of cookies, please see our Cookie Policy.

5.
Article V: Online Analytics and Advertising
Section 5.1: Analytics Services

We may use third-party web analytics services such as Google Analytics on our Services to collect and analyze usage information through cookies and similar tools, engage in auditing, research, or reporting, assist with fraud prevention, and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.

If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Section 5.2: Online Advertising Networks

The Services incorporate sophisticated third-party advertising technologies and platforms that facilitate the systematic delivery of targeted content and advertising materials both within our Services and across the broader digital ecosystem, including other websites that you visit and applications that you utilize. These advertising materials are generated and delivered based on comprehensive analysis of multiple data points and behavioral indicators, including but not limited to the specific content and context of the web pages you are currently viewing, Personal Information that you voluntarily provide such as demographic details including age and gender, your search queries and browsing patterns, statistical demographic data derived from your usage behavior, user-generated content that you create or interact with, and additional Personal Information that we collect through your ongoing use of the Services. The advertising content delivered to you may be formulated based on your immediate current online activity or derived from analysis of your cumulative digital behavior patterns over extended periods of time and across multiple websites and online services, with such advertisements being specifically customized and tailored to align with your demonstrated interests, preferences, and behavioral patterns.

Our Services enable authorized third-party entities, including advertising networks, data brokers, and advertising servers, to deploy cookies and other sophisticated tracking technologies directly onto your computer, mobile phone, tablet, or other electronic devices for the purpose of collecting comprehensive information about your digital activities and behaviors, including but not limited to your email address and other identifying information. These third-party entities, which include major technology and advertising companies such as Google, Meta, and numerous other similar organizations, are authorized to serve and deliver highly targeted advertisements to you as you navigate and utilize the Internet and various Internet-connected applications and services. These third parties maintain the capability to access, deploy, and manage their own proprietary cookies and tracking technologies on your computer, mobile phone, or other electronic devices that you use to access our Services, and they utilize this technological infrastructure to provide essential assistance and support in the delivery of targeted advertising activities and campaigns.

Section 5.3: Advertising Opt-Out Mechanisms

This Privacy Policy does not govern, nor do we have access to, cookies or other tracking technologies that non-affiliated third parties may place on the device you use to access the Services.

To opt out of Google Analytics for display advertising or to customize Google display network advertisements, you may visit the Google Ads Settings page. We exercise no control over these opt-out links or over whether any particular company elects to participate in such opt-out programs. We bear no responsibility for any choices you make through these mechanisms or for the continued availability or accuracy of such mechanisms. For additional methods to opt out of targeted advertising activities as permitted under applicable law, please refer to Article IX below.

You acknowledge and agree that if you exercise the aforementioned choices, you will continue to see advertising when using the Services; however, such advertising will not be tailored to you based upon your online behavior over time.

Section 5.4: Notice Concerning Do Not Track

Do Not Track, commonly referred to as "DNT," represents a privacy preference that users may establish within certain web browsers. We maintain our commitment to furnishing you with meaningful choices concerning information collected on our website for third-party purposes, and accordingly we provide the variety of opt-out mechanisms set forth above. Notwithstanding this commitment, we do not presently recognize or respond to browser-initiated DNT signals.

It should be noted that Do Not Track constitutes a distinct privacy mechanism separate from the user "preference signal" addressed in Article IX below. Such preference signal operates as a browser-based control indicating your election to opt out of processing your information for specified purposes, including without limitation the "sale" of your information or the disclosure thereof for targeted advertising purposes, as permitted under applicable laws.

6.
Article VI: Information Sharing and Disclosure

Company shall disclose your information in the following circumstances and manners:

Section 6.1: Corporate Affiliates and Subsidiaries

We may disclose information collected hereunder within Company's family of companies for the purposes of delivering products and services to you, ensuring a consistent level of service across our enterprise, and enhancing our products, services, and your overall customer experience. All affiliate companies are obligated to maintain privacy and security standards equivalent to those of Company and to utilize shared information solely for purposes consistent with the terms of this Privacy Policy.

Section 6.2: Service Providers and Business Partners

We may provide access to or disclose your information to select third parties who perform services on our behalf or in connection with our business operations. Such parties are granted access solely to perform the specified services and are contractually prohibited from utilizing your information for any other purposes. These service providers furnish various services to us, including without limitation billing operations, sales activities, marketing initiatives, product content development and features, advertising services, analytics, artificial intelligence and speech-to-text recognition and transcription services, research activities, customer service operations, data storage solutions, security services, fraud prevention measures, payment processing, and legal services. All service providers are contractually obligated to maintain appropriate security measures, utilize Personal Information exclusively for the specified purposes set forth in their agreements with us, and comply with all applicable privacy laws and regulations. We conduct periodic assessments of our service providers to ensure ongoing compliance with our privacy and security standards and contractual obligations.

Section 6.3: Protection of Company and Others

By utilizing the Services, you acknowledge and expressly agree that we may access, retain, and disclose the information we collect and maintain concerning you if required to do so by applicable law or based upon a good faith belief that such access, retention, or disclosure is reasonably necessary to comply with legal process including but not limited to subpoenas or court orders, enforce our Terms of Service, this Privacy Policy, or other contractual agreements with you, including investigation of potential violations thereof, respond to claims asserting that any content violates the rights of third parties, respond to your requests for customer service assistance, and protect the rights, property, or personal safety of Company, its agents and affiliates, its users, and the general public. This provision includes the exchange of information with other companies and organizations for purposes of fraud protection, spam and malware prevention, and similar purposes designed to maintain the integrity and security of our Services and protect our user community.

Section 6.4: Business Transfers and Corporate Changes

As we continue to develop and expand our business operations, we may acquire, merge with, or enter into partnership arrangements with other companies or entities. In connection with such transactions, including during the contemplation and negotiation of such transactions, user information may constitute one of the transferred assets. In the event that a portion or all of our assets are sold or transferred to a third party, customer information including your email address would likely constitute one of the transferred business assets. If such transfer becomes subject to additional mandatory restrictions under applicable laws, we shall comply with such restrictions and ensure that the acquiring entity agrees to maintain privacy protections substantially similar to those set forth in this Privacy Policy.

Section 6.5: Public Forums and User-Generated Content

When you choose to participate in public forums, comment sections, or other interactive features of the Services, any information you share becomes publicly available and may be viewed, collected, and used by other users and third parties. We cannot control how other parties use information you voluntarily make public, and you assume all risks associated with such public disclosures.

Section 6.6: Aggregate and De-identified Information

Company may share aggregate, statistical, or de-identified information that cannot reasonably be used to identify specific individuals. Such information may be used for research purposes, business analytics, marketing insights, and other commercial purposes without restriction, provided that the information has been properly anonymized and cannot be re-identified.

7.
Article VII: Data Security and Protection
Section 7.1: Security Framework

Company implements comprehensive technical, administrative, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, and destruction. Our security framework is based on industry best practices and is regularly updated to address emerging threats and vulnerabilities.

Section 7.2: Technical Safeguards

Our technical security measures include encryption of data in transit and at rest, secure network architectures and firewalls, access controls and authentication systems, regular security monitoring and threat detection, vulnerability assessments and penetration testing, secure software development practices, and incident response and recovery procedures.

Section 7.3: Administrative Safeguards

We maintain strict administrative controls including employee training and awareness programs, background checks for personnel with access to Personal Information, regular policy updates and compliance reviews, vendor management and oversight programs, and ongoing security audits and assessments.

Section 7.4: Limitations of Security

Despite our comprehensive security measures, no system is completely secure, and we cannot guarantee the absolute security of Personal Information. Internet and electronic communications inherently involve some security risks, and you acknowledge and accept these limitations when using the Services.

Article VIII: Data Retention and Deletion
Section 8.1: Retention Principles

Company retains Personal Information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on the type of information, its sensitivity, legal requirements, and business needs.

Section 8.2: Retention Criteria

Factors considered in determining retention periods include legal and regulatory requirements, contractual obligations, business operational needs, user account status and activity, data sensitivity and risk levels, and technical limitations of our systems.

Section 8.3: Data Deletion

When Personal Information is no longer needed, we securely delete or anonymize it using industry-standard methods. Some information may be retained in backup systems for limited periods for disaster recovery purposes, but such information is subject to the same security and privacy protections as active data.

8.
Article VIII: Data Retention and Deletion
Section 8.1: Retention Principles

Company retains Personal Information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on the type of information, its sensitivity, legal requirements, and business needs.

Section 8.2: Retention Criteria

Factors considered in determining retention periods include legal and regulatory requirements, contractual obligations, business operational needs, user account status and activity, data sensitivity and risk levels, and technical limitations of our systems.

Section 8.3: Data Deletion

When Personal Information is no longer needed, we securely delete or anonymize it using industry-standard methods. Some information may be retained in backup systems for limited periods for disaster recovery purposes, but such information is subject to the same security and privacy protections as active data.

9.
Article IX: Your Rights and Choices
Section 9.1: General Rights Framework

Depending on your jurisdiction, you may have the right to make certain requests regarding your "personal information" or "personal data" as such terms are defined under applicable law, and collectively referred to herein as "Personal Information" for the purposes of this Agreement. If you are a resident of California, please see our California Privacy Notice for additional disclosures about our practices and more information about your rights.

Section 9.2: Access and Portability Rights

You may have the right to ask us to inform you about the categories of Personal Information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your Personal Information, and the categories of third parties with whom we disclose Personal Information. You may also have the right to provide you access to and a copy of certain Personal Information we hold about you, receive your Personal Information in a commonly used format, and request that your Personal Information be transferred to another service provider where technically feasible.

Section 9.3: Correction and Update Rights

You may have the right to correct or update Personal Information we hold about you when such information is inaccurate or incomplete, and supplement incomplete information where necessary for the purposes for which it is processed.

Section 9.4: Deletion and Restriction Rights

You may have the right to delete certain Personal Information we have about you, subject to legal and contractual limitations, restriction of certain processing activities, and withdrawal of consent where our processing is based on your consent.

Section 9.5: Objection and Opt-Out Rights

You may have the right to object to or restrict processing of your information under certain circumstances, revoke your consent for the processing of your information where processing is based on consent, and opt out of the processing of your Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable. You also have the right to opt out of "sales" of your information and "processing" or "sharing" of your information for targeted advertising purposes as described below in Section 9.7.

Section 9.6: Exercise of Rights and Non-Discrimination

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Certain information may be exempt from such requests under applicable law. For example, we need to retain certain information to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request. If you would like to get additional information regarding your legal rights, make a privacy request, or delete your data, please submit a request through our designated portal or email us at [email protected]. Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

Section 9.7: Opting Out of Marketing Emails

You retain the absolute right to withdraw their consent to receive marketing communications from Company at any time and without penalty by utilizing the unsubscribe mechanism provided in each marketing email communication or by submitting a written request to our customer service team through the contact methods specified in our Privacy Policy. Upon receipt of an opt-out request, Company will process such request in accordance with applicable legal requirements within a reasonable period not to exceed ten (10) business days from the date of receipt to ensure complete removal from all relevant marketing databases and communication systems, accounting for the technical requirements of updating multiple systems, databases, and third-party service providers involved in marketing communications delivery. You should understand that opting out of marketing communications will not affect their receipt of essential administrative communications that are necessary for the provision of Services or maintenance of t

10.
Article X: Mobile Services and Communications
Section 10.1: Mobile Application Data

When you use our mobile applications, we may collect additional information specific to mobile usage, including device identifiers, mobile operating system information, application usage data, and mobile network information. This information helps us optimize the mobile experience and provide device-specific functionality.

Section 10.2: Mobile Communications

By providing your mobile phone number, you consent to receive communications from us via SMS, MMS, or voice calls. These communications may include service notifications, marketing messages, and customer support interactions, and may be delivered using automated systems.

Section 10.3: Mobile Carrier Information

We may share your mobile phone number with affiliated companies and authorized service providers for customer support, billing, collections, and message delivery purposes. Your mobile carrier's standard rates and fees may apply to all mobile communications.

Section 10.4: Mobile Number Changes

You agree to promptly notify us of any changes to your mobile phone number to ensure that communications intended for you are not misdirected to other individuals.

11.
Article XI: Legal Bases for Use of Your Information

The legal bases for utilizing your information as established in this Privacy Policy are set forth as follows:

Section 11.1: Contractual Necessity

We process your information where such use is necessary to perform our contractual obligations to you. This includes compliance with the Terms of Service governing our websites, which you accept by browsing our websites or registering for an account, as well as fulfillment of our contractual commitment to provide our Services to you, processing payments in connection with such Services, and delivering customer support as outlined in our Terms of Service and other applicable agreements between the parties.

Section 11.2: Legitimate Interests

We process your information where such use is necessary to pursue our legitimate business interests or the legitimate interests of third parties. These legitimate interests encompass providing security measures for our website and applications, operating our business and delivering our Services, processing and receiving payments, complying with applicable legal requirements and defending our legal rights in litigation or regulatory proceedings, preventing fraudulent activities, conducting customer identification and verification procedures for those individuals to whom we provide Services, performing business analytics and operational assessments, and pursuing legal rights and remedies available to us under applicable law.

Section 11.3: Legal Compliance

We process your information where we are legally required to do so in accordance with applicable legal obligations under European Union Member State law or other applicable jurisdictions. This includes compliance with applicable laws, regulations, legal processes, and government requests, including without limitation tax obligations, regulatory reporting requirements, and cooperation with law enforcement agencies and other governmental authorities.

Section 11.4: Consent

We process your information where we have obtained your explicit consent to do so, in accordance with the requirements and standards established under applicable privacy law and regulatory frameworks. Where required by applicable law, we obtain your explicit consent prior to processing Personal Information for specific purposes, including without limitation marketing communications or certain tracking activities. You retain the right to withdraw your consent at any time where processing is based solely upon such consent, subject to our continuing right to process such information on alternative legal bases where applicable.

12.
Article XII: International Transfer and Data Privacy Framework
Section 12.1: Data Processing Location and Transfer Principles

The information addressed in this Privacy Policy is processed within the United States by Company, whose principal United States office is located at 6300 Wilshire Blvd, Suite 1460, Los Angeles, CA 90048. Personal Information collected through the Services may be transferred to, processed in, and stored in countries other than your country of residence, including the United States, where our primary data processing facilities are situated. Such cross-border transfers are conducted in accordance with applicable data protection laws and the safeguards set forth herein.

Section 12.2: Data Privacy Framework Compliance

Company maintains compliance with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as established by the U.S. Department of Commerce. Company adheres to the EU-U.S. Data Privacy Framework Principles concerning the processing of personal data received from the European Union in reliance upon the EU-U.S. Data Privacy Framework and from the United Kingdom and Gibraltar in reliance upon the UK Extension to the EU-U.S. Data Privacy Framework. Company further adheres to the Swiss-U.S. Data Privacy Framework Principles concerning the processing of personal data received from Switzerland in reliance upon the Swiss-U.S. Data Privacy Framework. In the event of any conflict between the terms contained in this Privacy Policy and the EU-U.S. Data Privacy Framework Principles or the Swiss-U.S. Data Privacy Framework Principles, the applicable Principles shall govern. Additional information regarding the Data Privacy Framework program, including access to our certification, may be found at https://www.dataprivacyframework.gov/.

Section 12.3: Cross-Border Transfer Safeguards and Dispute Resolution

In accordance with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and Swiss-U.S. Data Privacy Framework Principles, Company commits to resolving complaints concerning your privacy and our collection or use of your personal data. Citizens of the European Union, United Kingdom, or Switzerland with inquiries or complaints regarding this Privacy Policy should initially contact Company at [email protected]. Company has undertaken additional commitments to refer unresolved privacy complaints under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and Swiss-U.S. Data Privacy Framework Principles to an independent dispute resolution mechanism operated by JAMS. If you do not receive timely acknowledgment of your complaint from Company, or if your complaint is not satisfactorily resolved by Company, you may visit the JAMS Data Privacy Framework Dispute Resolution website at https://www.jamsadr.com/dpf-dispute-resolution for additional information and to file a formal complaint.

Section 12.4: International Transfer Obligations and Liability

If you are located within the European Union or other regions with laws governing data collection and use that may differ from United States law, you are transferring information to a country and jurisdiction that does not maintain the same data protection laws as your jurisdiction. As described above, we may also subcontract the processing of your data to, or otherwise disclose your data to, other members within Company's corporate group, service providers, and business partners located in countries other than your country of residence, including the United States, in accordance with applicable legal requirements. Such third parties may be engaged in various activities, including without limitation the provision of Services to you, the processing of payment transactions, and the provision of technical support services. By providing us with your information, you acknowledge and consent to any such transfer, storage, or use. Company shall take reasonable and appropriate steps necessary to ensure that any third party acting as a "data processor" under European Union and Swiss legal terminology processes the personal data we entrust to them in a manner consistent with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and Swiss-U.S. Data Privacy Framework Principles. Company may be held liable in cases of onward transfer to third parties of data belonging to European Union, United Kingdom, and Swiss individuals received pursuant to the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and Swiss-U.S. Data Privacy Framework, respectively, where such third parties process such data in a manner inconsistent with the applicable Framework Principles. Where applicable under governing law, you may submit a complaint to the data protection supervisory authority in the country where you reside. Alternatively, you may pursue remedies through local courts if you believe your rights have been violated under applicable data protection legislation.

13.
Article XIII: Children's Privacy Protection
Section 13.1: Age Restrictions

The Services are intended for general audiences and are not designed for or directed to children under the age of thirteen (13) in the United States or under the age of sixteen (16) in the European Union. We do not knowingly collect Personal Information from children below these age thresholds without appropriate parental consent.

Section 13.2: Parental Consent Requirements

If we become aware that we have collected Personal Information from a child without proper parental consent, we will take immediate steps to delete such information from our systems. Parents and guardians may contact us to review, modify, or delete their child's Personal Information.

Section 13.3: Additional Protections

We implement additional safeguards for any information that may be collected from minors, including enhanced security measures, limited data processing, and strict access controls. We also comply with all applicable local laws regarding the protection of children's privacy.

14.
Article XIV: Third-Party Links and Services
Section 14.1: External Links and Content

The Services may contain links to third-party websites, applications, and services that are not owned or operated by Company. These external links are provided for your convenience and information, but we do not control or endorse the content, privacy practices, or security measures of such third parties.

Section 14.2: Third-Party Social Features

Social media features and widgets integrated into the Services are governed by the privacy policies of the respective social media platforms. Your interactions with these features may result in the collection and sharing of information by third parties according to their own terms and policies.

Section 14.3: Disclaimer of Responsibility

Company is not responsible for the privacy practices, security measures, or content of third-party websites and services. We encourage you to review the privacy policies and terms of service of any third-party services you choose to use.

15.
Article XV: Policy Modifications and Updates
Section 15.1: Amendment Rights

Company reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our practices, legal requirements, technological developments, or business operations. All amendments will be effective upon posting unless otherwise specified.

Section 15.2: Notice of Material Changes

For material changes that significantly affect your rights or our processing practices, we will provide advance notice through appropriate channels, which may include email notifications, prominent website notices, or in-application alerts, as required by applicable law.

Section 15.3: Continued Use Constitutes Acceptance

Your continued use of the Services following the posting of Privacy Policy changes constitutes your acceptance of such modifications. If you do not agree to the updated terms, you must discontinue use of the Services.

Section 15.4: Version Control

We maintain version control for this Privacy Policy and indicate the effective date of the current version. You are encouraged to review this Privacy Policy periodically to stay informed about our information practices.

16.
Article XVI: Contact Information and Dispute Resolution
Section 16.1: Primary Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our privacy practices, you may contact Company using the following methods:

Address: 6300 Wilshire Blvd, Suite 1460, Los Angeles, CA 90048
Email: [email protected]
General Support: [email protected]

Section 16.2: Privacy Request Processing

Privacy-related requests will be processed in accordance with applicable legal requirements and within the timeframes specified by law. We may require identity verification and additional information to process certain requests to ensure the security and accuracy of our response.

Section 16.3: Supervisory Authority Rights

If you are located in the European Union, United Kingdom, or other jurisdictions with data protection supervisory authorities, you have the right to lodge complaints with the relevant supervisory authority regarding our processing of your Personal Information. This right exists independently of any other administrative or judicial remedy you may have.

Section 16.4: Legal Remedies

Nothing in this Privacy Policy limits your rights to seek legal remedies available under applicable privacy laws or affects any statutory rights that cannot be waived by agreement. You retain all rights provided by law that are not explicitly addressed in this Privacy Policy.

17.
Article XVII: Complete Agreement and Final Provisions
Section 17.1: Entire Agreement

This Privacy Policy represents the complete agreement between you and Company regarding the privacy aspects of the Services and supersedes all prior communications, representations, and agreements relating to privacy matters. Any modifications to this agreement must be made in accordance with the amendment procedures outlined in Article XV.

Section 17.2: Severability

If any provision of this Privacy Policy is found to be unenforceable or invalid under applicable law, such provision shall be modified to the minimum extent necessary to make it enforceable, or if modification is not possible, such provision shall be severed from this Privacy Policy. The remainder of this Privacy Policy shall remain in full force and effect.

Section 17.3: Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of California, United States, without regard to its conflict of law principles. Any disputes arising under this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located in Los Angeles County, California.

Section 17.4: Effective Date and Acknowledgment

This Privacy Policy is effective as of the date set forth above. By using the Services after such date, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy in its entirety.