When accessing the Website, the Company will learn certain information about you, both automatically and through voluntary actions you may take, during your visit. This policy applies to information we collect on the Website and in email, text, or other electronic messages between you and the Website.
RefresHR provides some services to you through other organizations, such as schools and businesses. When your organization gives you access to our services or you use RefresHR with an account tied to your organization, and where we work solely on their behalf, this Privacy Statement does not apply. Instead, your use of those services is subject to their privacy policies. We provide protections required by the Federal Educational Rights Privacy Act (FERPA) for services provided to schools subject to FERPA. When your organization gives you a voucher or offer code that lets you create an account directly with RefresHR, we are not acting on behalf of those organizations and this Privacy Statement will apply.
Because RefresHR is a learning environment for children, we take additional measures to safeguard children’s privacy, including for children under the age of 18. Please see our children’s privacy statement below.
INFORMATION WE COLLECT ABOUT YOU
When you access the Website, the Company will learn certain information about you during your visit.
Information You Provide To Us. The Website provides various places for users to provide information. We collect information that users provide by filling out forms on the Website, communicating with us via contact forms, responding to surveys, search queries on our search feature, providing comments or other feedback, and providing information when ordering a product or service via the Website.
We use information you provide to us to deliver the requested product and/or service, to improve our overall performance, and to provide you with offers, promotions, and information.
Information We Collect Through Automatic Data Collection Technology. As you navigate through our Website, we may use automatic data collection technologies including Google Analytics to collect certain information about your equipment, browsing actions, and patterns. This will generally include information about your location, your traffic pattern through our website, and any communications between your computer and our Website. Among other things, we will collect data about the type of computer you use, your Internet connection, your IP address, your operating system, and your browser type.
The information we collect automatically is used for statistical data and will not include personal information. We use this data to improve our Website and our service offerings. To the extent that you voluntarily provide personal information to us, our systems will associate the automatically collected information with your personal information.
Similar to other commercial websites, our website utilizes a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail, and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site. For further information see the email policies below.
We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Disclosure of Your Information.
We will maintain the information you send via e-mail in accordance with applicable federal law.
In compliance with the CAN-SPAM Act, all e-mails sent from our organization will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.
Our emails provide users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at anytime.
Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.
HOW AND WHY WE COLLECT INFORMATION
The Company collects your information in order to record and support your participation in the activities you select. If you register to download a book or resources, sign up for our newsletter, and/or purchase a product from us, we collect your information. We use this information to track your preferences and to keep you informed about the products and services you have selected to receive and any related products and/or services. As a visitor to this Website, you can engage in most activities without providing any personal information. It is only when you seek to download resources and/or register for services that you are required to provide information.
If you are outside the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any products sold by the Company on this Website, we will automatically enroll you to receive our free email newsletter. If you do not wish to receive this newsletter, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to su[email protected] requesting to unsubscribe from future emails.
If you are in the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any products sold by the Company on this Website, we will only enroll you to receive our free email newsletter if you affirmatively consent to it. If you do not wish to receive this newsletter, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to su[email protected] requesting to unsubscribe from future emails.
HOW DO WE USE THE INFORMATION THAT YOU PROVIDE TO US?
We use personal information for purposes of presenting our Website and its contents to you, providing you with information, providing you with offers for products and services, providing you with information about your subscriptions and products, carrying out any contract between you and the Company, administering our business activities, providing customer service, and making available other items and services to our customers and prospective customers.
From time-to-time, we may use the information you provide to us to make you offers to purchase products and services provided by third parties in exchange for a commission to be paid to us by such third parties. Should you opt to take part in such promotions, the third parties will receive your information.
From time-to-time, we may use the information you provide to us to display advertisements to you that are tailored to your personal characteristics, interests, and activities.
DISCLOSURE OF YOUR INFORMATION
As a general rule, we do not sell, rent, lease or otherwise transfer any information collected whether automatically or through your voluntary action.
We may disclose your personal information to our subsidiaries, affiliates, and service providers for the purpose of providing our services to you.
We may disclose your personal information to a third party, including a lawyer or collection agency, when necessary to enforce our terms of service or any other agreement between you and the Company.
We may provide your information to any successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s asserts and/or business.
We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights or when compelled by a court or other governmental entity to do so.
HOW DO WE PROTECT YOUR INFORMATION AND SECURE INFORMATION TRANSMISSIONS?
We employ commercially reasonable methods to ensure the security of the information you provide to us and the information we collect automatically. This includes using standard security protocols and working only with reputable third-party vendors. Email is not recognized as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information is never transmitted via email.
The Company may use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.
For site security purposes and to ensure that this service remains available to all users, the Company uses software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.
VISITORS’ GDPR RIGHTS
If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Those rights include:
We will retain the any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) the Company decides that the value in retaining the data is outweighed by the costs of retaining it.
You have the right to request access to your data that the Company stores and the rights to either rectify or erase your personal data.
You have the right to seek restrictions on the processing of your data.
You have the right to object to the processing of your data and the right to the portability of your data.
To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.
We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
Children's Privacy Notice
This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by Learners including children under the age of 13 (“Child” or “Children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding Children’s Personal Data. For more information about COPPA and general tips about protecting Children’s online privacy, please visit OnGuard Online.
Collection: RefresHR collects Personal Data about Children directly from Parents and, when we have verified parental consent of Parents, directly from Children through our website and mobile app. Children can only attend self-paced, live workshops or coaching sessions if their Parents enroll them. Parents provide us with the Child’s name and age. Parents may additionally provide us with descriptions of the type of schooling their Child attends, local time zone, and additional notes for the Coach. In addition, Children may share information about themselves during workshops. We may collect other Personal Data about Children as described in our general Privacy Notice, with the exception that we do not collect payment information from Children or allow third parties to use Personal Data collected through analytics or advertising cookies for their own purposes. We also do not condition participation in our Services for Children on the collection of more Personal Data than is reasonably necessary. Children may also share information about themselves during workshops and private coaching and when reporting emergency safety and compliance issues.
Use and Disclosure: Once we obtain verified parental consent, we may use and share Personal Data collected from Children for many of the same purposes described in the general Privacy Notice. We recommend Workshops, Live Events, and new features to Parents and Children if parents add Childrens email to our subscriber list or provided directly in links. We may send these messages to Children and Parents through push notifications if Parents enable this feature in the Website or mobile app. We may also send emails to Parents about those recommendations and surveys and informational emails to Parents and Children.
RefresHR allows you to share, the name, age, postal address, local time zone, and any notes Parents have provided about their Child to allow the Coach to provide Self-paced Workshops, facilitate Live Workshops, and deliver supplies to Children. Children can also privately message the coach in the Workshops they’re enrolled in. Parents should consider using virtual backgrounds for their Children if they have concerns about posting images of their home and family members. Children may also share information about themselves with the Coach and the rest of their classmates during the Workshop session voluntarily, including content, images, and videos they may upload and share with their Coach and classmates. While RefresHR takes reasonable steps to monitor certain communications and posts, please note that we are not able to control or monitor all Personal Data your Child may share with the coach or other classmates, nor what those third parties ultimately do with that information.
Parents can also enroll Children in chat sessions. For safety reasons, we ask for the camera to be on before they can participate. We do this to verify that participants are Children. The Coach may or may not participate or lead workshops but no other adults are allowed to interact with Children in live workshops. Children interact with other children in group chat learning sessions on various topics. Children can share messages, posts, and other content with other Learners.
We urge you to talk to your Children to follow our community standards when posting content and messages in Live Workshops. You should encourage your Children to also think about their own privacy and safety when choosing what to share with others. In particular, Children should be encouraged to avoid sharing Personal Data like their address or contact information with other Children in Live Workshops.
At times, we may allow Children and Parents to submit content, along with other information about the Child (like age, first name or initials and city, state, and country) that you may allow us to display publicly. Parents should review Children’s submissions and avoid uploading any private information in the Content about the Children, family members, or others. RefresHR is not responsible for what other third parties do with information you choose to share publicly.
We may ask Child Learners and their Parents to use third-party sites and services. Parents should review the privacy notices for those third party sites and services to understand their privacy practices. These third parties are not our service providers, and we are not responsible for and may not have reviewed those third-party sites and services.
Parental Consent: RefresHR sends a direct notice with these privacy disclosures and obtains verifiable parental consent before collecting, using, and sharing Personal Data from your Child as described in this Notice. RefresHR requires that you provide your credit card information to verify you and to register your Child for and pay for an RefresHR Class. If you do not consent or withdraw consent, then we will not collect, use, or disclose any Personal Data about your Child, except as needed for legal compliance and enforcement purpose, and your Child will not be allowed to use the Services in any way. If you do not provide consent within a reasonable time from the date the direct notice was sent, and are not using our services for any other purposes, such as for teen children, we will also delete your online contact information from our records.
Parental Choices and Controls: At any time, you can review and refuse to permit us to collect further Personal Data from your Children in association with your account. You can also request that we delete from our records the Personal Data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may review and update certain of your Child’s information by logging onto your account. In your account, you can review topics of interest we have inferred based on your Child’s likes and past classes. You can choose to opt-out of recommendations based on your Child’s activities and instead choose the learning topics you want to hear about. You can contact RefresHR to request access to, change, or delete your Child’s Personal Data, or revoke consent for our collection, use, and sharing of Personal Data, by sending an email to us at [email protected]. A valid request to delete Personal Data will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete Personal Data collected from Children when it is no longer needed for the purpose for which it was collected.
For users of our mobile app, Parents can choose permissions to allow push notifications to, and camera and photo access by, Children. Parents should consider enabling parental controls to help prevent Children from changing permissions you have chosen. Most devices provide ways to set these controls through device settings.
Effective as of September 25, 2022
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